Privacy Policy

Last updated: October 1^st, 2026

Overview

GFSC Life Inc. ("GFSC Life," “we,” “our,” or “us”) including when operating under its trade name, North Cover (the “Trade Name”), respects your privacy and is committed to protecting the Personal Information entrusted to us. We handle Personal Information in accordance with applicable federal and provincial private-sector privacy laws, including the Personal Information Protection and Electronic Documents Act and, where applicable, the Personal Information Protection Acts of Alberta and British Columbia.

This Privacy Policy (the “Policy”) explains how we collect, use, disclose, retain, and safeguard Personal Information when you interact with us as a prospective or current customer, insured person, policyholder, beneficiary, claimant, website or portal user, or job applicant. It applies to our websites, online accounts and forms, telephone calls, emails, text messages, social media interactions, and other services that link to or refer to this Policy. It should be read together with any more specific notice or consent that we provide when we collect Personal Information.

GFSC Life distributes and services life insurance products issued by the insurer identified in the applicable quote, application, policy, or other product material. References in this Policy to “MIB” mean MIB Group, Inc. and its affiliates, a not-for-profit membership organization of life and health insurers based in the United States that operates an information exchange used to detect errors, omissions, and misrepresentations in insurance applications. An insurer, reinsurer, MIB, or another organization may independently control Personal Information that it receives and may provide its own privacy notice. This Policy describes GFSC Life’s practices and responsibilities.

At a glance

• What we collect: Depending on your interaction with us, we may collect identity and contact information; insurance, health, lifestyle, financial, payment, beneficiary, and claim information; account and policy records; communications and recordings; SMS consent and message data; and website and device information.
• Why we use it: We use Personal Information to provide information and quotes, assess needs, facilitate applications and underwriting, administer and service policies, process payments and claims, verify identity, communicate with you, conduct quality assurance and training, prevent fraud, comply with legal and regulatory obligations, improve our services, and market to you where permitted and with any required consent.
• Who receives it: We disclose Personal Information to insurers, reinsurers, MIB, and service providers that support our operations. We may also disclose it to regulators, government institutions, law enforcement, courts, professional advisers, and other parties where permitted or required by law. We limit disclosures to what is reasonably necessary for the relevant purpose.
• SMS information: Except for telecommunications carriers and service providers acting solely on our behalf to deliver and administer text messages, or where required or permitted by law, SMS opt-in information and consent are not shared with or sold to third parties or affiliates.
• Where information is processed: Personal Information may be processed in Canada and in other countries, including Australia, New Zealand, India, and the United States, where it may be subject to the laws of those jurisdictions.
• Your choices and rights: Subject to applicable law, you may request access to or correction of your Personal Information, withdraw consent, change your communication choices, and raise a privacy concern or complaint.

The sections below provide more detail. This summary does not replace the full Policy or a specific notice or consent provided in connection with an insurance application, policy, claim, or other service.

Accountability and scope

Our Privacy Officer is responsible for overseeing our privacy program and our compliance with applicable privacy laws. We remain accountable for Personal Information under our control, including information transferred to a service provider for processing on our behalf. We use contractual and other measures designed to require service providers to protect that information and use it only for authorized purposes. GFSC Life is part of the Greenstone group of companies. Personnel and systems of our affiliate Greenstone Financial Services Canada may process Personal Information on our behalf, and this Policy applies to that processing.

This Policy does not govern an independent organization’s handling of Personal Information when that organization controls the information for its own purposes. This includes an insurer, reinsurer, MIB, or a third-party website. We are, however, responsible for our decision to disclose Personal Information and for the handling of information by a service provider acting on our behalf.

What Personal Information do we collect about you

“Personal Information” means information about an identifiable individual or information that may reasonably be linked to an identifiable individual. The information we collect depends on the products or services you request and how you interact with us. It may include:

• Identity, contact, and demographic information, such as your name, date of birth, sex or gender where relevant to an insurance application, marital or family status, residential and mailing address, postal code, telephone number, email address, language preference, and information used to verify your identity.
• Insurance and underwriting information, such as your insurance needs and objectives, existing or prior coverage and applications, occupation, income, health and medical history, family health history, medications, tobacco or nicotine use, lifestyle, travel, hobbies, driving information, and other information relevant to eligibility, suitability, underwriting, or a claim.
• Financial and payment information, such as income and affordability information, bank account or payment details, billing information, premium history, and transaction records.
• Policy, beneficiary, and claim information, such as quote and application details, customer and policy numbers, coverage and premium information, transaction and service history, and information about beneficiaries and claimants, including their names, contact information, dates of birth, and relationship to an insured person or policyholder.
• Communications and recordings, such as emails, letters, chat and text messages, call and message metadata, recordings of telephone calls, and, where applicable, recordings of the computer screen used by our representative during a customer call.
• Account and security information, such as login credentials, authentication information, security questions, one-time verification codes, and records of access to an online account.
• SMS information, such as your mobile telephone number; the date, time, and method of opt-in or opt-out; the messages sent or received; delivery status; and HELP or STOP requests.
• Website, device, and advertising information, such as your Internet Protocol address, browser and operating system, device identifiers, cookie identifiers, pages viewed, links selected, referring and exit pages, and the date and time of an interaction.
• Recruitment information, such as your resume, employment and education history, qualifications, references, areas of interest, and information from a professional profile or personal website that you provide to us or authorize us to review.

We may also collect other Personal Information with your consent or as permitted or required by law. We do not collect every category of information in every interaction. When you provide Personal Information about another individual, such as a beneficiary or claimant, you should ensure that you are permitted to provide it. We use that information only for the purposes described in this Policy and any applicable notice or consent.

How do we collect Personal Information

We collect Personal Information directly from you when you request information or a quote, complete a form or insurance application, speak with one of our representatives, use a website or online account, send us an email or text message, make a payment or claim, participate in a survey, interact with our social media pages, apply for employment, or otherwise communicate with us.

We may also collect Personal Information from other sources where permitted by law, including lead providers and online comparison platforms through which you have requested contact or information; insurers, reinsurers, MIB and MIB member insurers; health professionals and paramedical service providers; the ministry or authority responsible for transportation or motor vehicle records in your jurisdiction; payment, identity verification, fraud prevention, and technology service providers; publicly available sources permitted by law; and references or recruitment providers.

Some website and device information is collected automatically through cookies, pixels, tags, logs, and similar technologies. More information is provided under Cookies and similar technologies below. We collect Personal Information by fair and lawful means and identify the purposes at or before collection, unless an exception under applicable law applies.

How do we use Personal Information

We use Personal Information for the following purposes:

• responding to requests for information, advice, or quotes and assessing insurance needs and objectives;
• preparing, receiving, reviewing, and processing insurance applications and supporting the insurer’s underwriting and policy-issuance processes;
• verifying the accuracy and completeness of application, underwriting, and claim information, including by checking appropriate sources and making or receiving reports to or from MIB where required or authorized;
• administering and servicing policies, accounts, beneficiaries, payments, claims, renewals, changes, cancellations, and other customer requests;
• verifying identity, authenticating account access, and sending one-time verification codes;
• communicating with you by telephone, mail, email, SMS, or another channel about a request, application, policy, payment, claim, account, complaint, security matter, or other service interaction;
• responding to questions, concerns, complaints, access requests, and correction requests;
• operating, securing, troubleshooting, evaluating, and improving our websites, accounts, systems, products, services, and customer experience;
• conducting analytics, measuring advertising effectiveness, and providing relevant advertising or marketing, subject to your choices and any consent required by law;
• detecting, investigating, preventing, or suppressing fraud, unauthorized activity, security incidents, breaches of agreements, and other prohibited or unlawful activity;
• meeting contractual, legal, regulatory, licensing, audit, recordkeeping, reporting, and risk-management requirements;
• evaluating candidates and administering recruitment;
• planning or completing a proposed or actual business transaction, where permitted by law; and
• other purposes that we identify when we collect the information, that are consistent with the original purposes, to which you consent, or that are permitted or required by law.

Consent and privacy choices

We obtain consent where required by law. Consent may be express or implied, depending on the sensitivity of the information, your reasonable expectations, and the circumstances. We generally seek express consent to collect, use, or disclose health, medical, financial, and other sensitive information. We may also collect, use, or disclose Personal Information without consent where applicable law permits or requires it.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. We will explain any reasonably foreseeable consequences. For example, if information is necessary to provide a quote, process an application or claim, administer a policy, verify identity, or meet a legal requirement, withdrawing consent may limit our ability to provide the related product or service. Withdrawal does not affect handling that occurred before it took effect, and we may continue to retain or handle information where permitted or required by law.

Optional marketing choices are not a condition of obtaining an insurance product. You may unsubscribe from marketing emails using the link in the message and may stop marketing text messages by replying STOP. You may still receive non-marketing communications that are necessary to respond to you or administer an application, policy, account, payment, claim, or legal obligation, through a channel permitted by law.

Call and screen recordings

We record customer telephone calls and, where applicable, the computer screen used by our representative during the call. We provide notice of recording and identify its purposes at or before the recording begins. Recordings may include Personal Information that you provide and information displayed or entered by the representative while assisting you.

We use recordings only for identified purposes, including quality assurance, training and coaching, recordkeeping, verifying information and instructions, security and fraud prevention, investigating and resolving complaints or disputes, and meeting insurer, contractual, legal, and regulatory requirements. Access is restricted to authorized personnel and service providers, and recordings are retained in accordance with our retention requirements. If you object to a recording, tell the representative, who will explain the alternatives available to you, such as continuing the interaction in writing or through another channel, and the effect on our ability to complete your request.

Telephone contact

We sell and service our products by telephone. If you request a quote or information through our websites, a lead provider, or an online comparison platform, we may call you at the telephone number you provided to follow up on your request. We make telemarketing calls in accordance with the CRTC Unsolicited Telecommunications Rules, including the National Do Not Call List Rules. You may ask us at any time not to call you again, and we will add your telephone number to our internal do-not-call list within the period required by law. An internal do-not-call request does not prevent calls that are necessary to administer an existing application, policy, or claim, or to respond to a request you have made.

SMS and mobile information

If you provide a mobile telephone number and opt in to receive text messages, we may send messages that you request or consent to receive. Depending on the program, these may include one-time identity verification codes, follow-up information requested during a customer call, and information about an application, policy, account, payment, claim, or service request. We send marketing text messages only where permitted by law and with any consent required by law.

By providing your mobile number and consenting to receive text messages, you may receive a one-time identity-verification message from GFSC Life under its Trade Name, containing our company name, website, and customer service contact information. Message frequency varies. Message and data rates may apply. Reply HELP for help or call 1-844-203-85231-844-203-8523. Reply STOP to cancel at any time. Carriers are not liable for delayed or undelivered messages.

Except for telecommunications carriers and service providers acting solely on our behalf to deliver and administer text messages, or where required or permitted by law, SMS opt-in information and consent, including your mobile telephone number, are not shared with or sold to third parties or affiliates. Our service providers may use this information only to provide services to us and may not use it for their own marketing or promotional purposes.

You may reply STOP to cancel text messages and reply HELP for help. Opting out of SMS does not cancel an insurance policy or prevent us from contacting you through another channel where permitted by law.

How do we share Personal Information

We disclose or transfer Personal Information only for purposes that a reasonable person would consider appropriate, with consent where required, or as permitted or required by law. Recipients may include:

• Insurers, reinsurers, MIB, and insurance service providers: We disclose information needed to assess, underwrite, issue, administer, reinsure, service, or adjudicate an insurance application, policy, or claim. MIB and insurers may use information to verify application, underwriting, and claim information in accordance with applicable notices, consents, laws, and their own privacy practices.
• Affiliates and service providers acting for us: We use service providers for hosting, data storage, customer service, telephony and SMS, email delivery, payment processing, identity verification, analytics, advertising, information security, records management, professional advice, audit, and other operational support. We disclose only information reasonably necessary for the service and require appropriate confidentiality, security, use, retention, and breach-notification terms. Affiliates receiving information to perform services for us are subject to the same restrictions.
• Regulators, government institutions, courts, and other legal recipients: We may disclose information to insurance, privacy, law-enforcement, tax, or other authorities; a court, tribunal, or dispute-resolution body; our legal or other professional advisers; or another organization where reasonably necessary to comply with law, a warrant, subpoena, court order, regulatory requirement, or lawful request, or to investigate or prevent fraud, security incidents, breaches of agreements, or unlawful activity.
• Parties to a business transaction: We may disclose information in connection with a proposed or completed financing, reorganization, merger, sale, or transfer of all or part of our business or assets, subject to the safeguards and conditions required by law.
• Other parties you authorize: We may disclose information at your direction, with your consent, or where otherwise permitted or required by law.

An insurer, reinsurer, MIB, or another recipient acting independently is responsible for its own subsequent handling of the information under applicable law. Our responsibility for selecting and making a disclosure is not affected by that independent responsibility.

Processing outside Canada

Personal Information may be stored or processed in Canada and may be accessed or processed by service providers, affiliates, insurers, reinsurers, or MIB in other jurisdictions. MIB is located in the United States, and insurers and reinsurers may process information outside Canada. The countries in which our current service-provider arrangements may involve processing include Australia, New Zealand, India, and the United States. While information is in another jurisdiction, it may be subject to that jurisdiction’s laws and may be accessible to courts, law enforcement, national security authorities, or regulators in accordance with those laws.

We use contractual and other measures designed to provide a level of protection comparable to the protection we provide in Canada. You may contact our Privacy Officer for information about our use of service providers outside Canada and our policies concerning those service providers.

How long do we retain Personal Information

We retain Personal Information only for as long as reasonably necessary to fulfil the purposes for which it was collected and to meet contractual, legal, regulatory, limitation-period, audit, fraud-prevention, complaint, dispute, and recordkeeping requirements. Retention periods vary according to the type and sensitivity of the information, whether an inquiry or application results in a policy, the life cycle of a policy or claim, and the requirements that apply to the record.

When Personal Information is no longer required, we securely destroy or delete it, or render it anonymous so that it can no longer be used to identify an individual, subject to reasonable backup and system-deletion cycles and any legal or regulatory hold.

Accuracy

We take reasonable steps to keep Personal Information as accurate, complete, and up to date as necessary for the purposes for which it is used. You can help by providing accurate information and telling us when relevant information changes. You may request a correction as described below.

How do we safeguard Personal Information

We use physical, organizational, contractual, and technological safeguards appropriate to the sensitivity, amount, format, and location of the Personal Information and the risks to it. Health, medical, financial, identity, and insurance information generally require a high level of protection. Our safeguards include, as appropriate:

• role-based and need-to-know access controls, authentication measures, and periodic access reviews;
• encryption and secure transmission or storage measures where appropriate;
• confidentiality obligations, privacy and security policies, and employee training;
• physical security, monitoring, logging, testing, and incident-response processes;
• service-provider due diligence, contractual protections, and proportionate oversight; and
• retention controls and secure disposal practices.

No method of transmitting or storing information is completely secure. If we become aware of a privacy or security breach, we take steps to contain and investigate it, reduce the risk of harm, and meet applicable recordkeeping, reporting, and notification obligations. Where required by law, we notify affected individuals and the appropriate privacy regulator as soon as feasible.

Your privacy rights

Depending on the law that applies, you may exercise the following rights, subject to applicable exceptions and limitations:

• Access: You may ask whether we hold Personal Information about you, how we have used it, and the organizations or types of organizations to which we have disclosed it. You may also request access to that information in an understandable form.
• Correction: You may challenge the accuracy or completeness of Personal Information and ask us to correct it. If we do not make a requested correction, we will annotate the record where required by law.
• Withdrawal of consent and communication choices: You may withdraw consent where we rely on consent, unsubscribe from marketing, and change your email or SMS choices, subject to the qualifications described in this Policy.
• Complaint: You may raise a concern about our privacy practices with our Privacy Officer and may complain to the privacy regulator that has jurisdiction.

How to make an access or correction request

Send a written request to our Privacy Officer using the contact information below and provide enough detail for us to identify the relevant records. We may ask for information reasonably necessary to verify your identity and authority before responding. We use verification information only for that purpose.

We ordinarily respond within 30 days and, in all cases, within the period required by applicable law. If the law permits an extension and we need one, we will tell you why and when you can expect a response. Access is provided at minimal or no cost unless applicable law permits a reasonable fee. If a fee may apply, we will give you an estimate before proceeding.

Applicable law may require or permit us to withhold information, including information protected by legal privilege, confidential commercial information, or information that would reveal Personal Information about another individual. If we cannot provide access or make a requested correction, we will explain the reason and available recourse unless the law restricts us from doing so.

Complaints to a privacy regulator

We encourage you to contact our Privacy Officer first so that we can try to resolve your concern. You may also contact the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of Alberta, or the Office of the Information and Privacy Commissioner for British Columbia, as applicable. You will not be penalized for raising a privacy concern in good faith.

Cookies and similar technologies

Our websites, online services, emails, and advertisements may use cookies, pixels, tags, logs, local storage, and similar technologies. These technologies may collect information such as an IP address, browser and device type, operating system, cookie or device identifier, referring page, pages and links used, and the date, time, and duration of an interaction.

We use these technologies for purposes that may include:

• Essential functions, such as security, fraud prevention, network management, account login, and remembering information needed to provide a requested service;
• Preferences and functionality, such as remembering settings and improving convenience;
• Analytics and performance, such as understanding how visitors use our websites, diagnosing problems, and improving content and services; and
• Advertising and measurement, such as measuring campaign performance and delivering or assessing advertising that may be relevant to inferred interests, subject to your choices and applicable law.

We may permit analytics and advertising providers to set or read their own technologies. Those providers may receive device and usage information and may handle it under their own privacy policies. We do not use health, medical, financial, application, policy, or claim information to create profiles for interest-based advertising.

Where required, we seek consent for non-essential cookies and similar technologies and provide a way to change your choices. You may also adjust browser or device settings to block or delete cookies. Blocking essential technologies may affect website or account functionality. An opt-out should not prevent access to a service unless the technology is necessary to provide or secure it.

Young persons

Our websites are not directed to persons under 16. We do not knowingly collect Personal Information directly from a person under 16 through a website without the consent of a parent or guardian. We may collect information about a minor as an insured person, beneficiary, claimant, or dependant where permitted by law and reasonably necessary for an insurance-related purpose.

Third-party websites and services

Our websites may link to websites or services operated by third parties. This Policy does not apply to an independent third party’s privacy practices. Review the third party’s privacy notice before providing Personal Information. A link does not mean that we control or endorse the third party’s privacy practices.

Changes to this Privacy Policy

We may update this Policy to reflect changes in our practices, services, or legal obligations. We will post the revised Policy and update the “Last updated” date at the top of this Policy. If a change is material, we will provide additional notice or obtain consent where appropriate or required by law. We do not use a policy update to authorize a materially different collection, use, or disclosure where new consent is required.

Contact Us

Contact our Privacy Officer to ask a privacy question, exercise a privacy right, make a complaint, or request information about our service providers outside Canada. For privacy matters relating to North Cover, a Trade Name of GFSC Life Inc., please use the contact points below.