Privacy Policy

Sterling Benefits ("Sterling Benefits," "we," "us," or "our") is an independent group benefits insurance brokerage operated by Ralph Gardner, based in Kelowna, British Columbia. This Privacy Policy explains what personal information we collect through our website at sterlingbenefits.ca (the "Site"), why we collect it, how we use and protect it, and the choices and rights you have. It applies to visitors, prospective clients, and clients who interact with the Site, including anyone who submits a form, requests a quote, uploads a document, or books a consultation.

1. Personal Information We Collect

We collect personal information directly from you when you voluntarily provide it through the Site. Depending on which forms you use, this may include:

• Contact information: your name, email address, and phone number.
• Business information: your company or organization name, industry, and number of employees.
• Quote and plan-comparison details: information about your current or prospective group benefits needs, including, where you choose to submit an employee census, the name, date of birth, gender, marital status, province of residence, occupation, hours worked, pay, and requested coverage type for each employee you include (including yourself, if applicable). This information is provided by you, as the employer or an authorized representative, on behalf of your employees for the sole purpose of obtaining an insurance quote.
• Documents you upload: if you use our plan comparison tool, the benefits booklet, renewal letter, or billing/premium statement you choose to upload, which may contain additional information about your existing coverage and business.
• Scheduling information: if you book a consultation, the name, email, and any details you provide through our scheduling tool (Calendly).
• Communications: any additional information you provide when you contact us by email or phone, or in the free-text fields of our online assessment.

We do not knowingly collect health information, medical history, or other special categories of personal information through the Site. The employee census fields above relate to eligibility and rating factors used in group insurance underwriting (such as age, sex, and occupation), not medical or health status.

2. How We Use Your Information

We use the personal information we collect to:

• Respond to your inquiries and provide the quotes, plan comparisons, or benefits assessments you've requested;
• Prepare and submit quote requests to insurance carriers and third-party administrators on your behalf;
• Schedule and conduct consultations;
• Maintain records as required for insurance brokerage compliance and regulatory purposes;
• Communicate with you about your inquiry, quote, or existing coverage, including by text message or email where you've consented to receive such messages;
• Improve our Site and the services we offer; and
• Comply with applicable law.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects, and we do not sell your personal information to third parties.

3. How We Share Your Information

We disclose personal information only where reasonably necessary to provide our services, and otherwise only with your consent or as required by law. This includes:

• Insurance carriers and third-party administrators: to obtain quotes, arrange coverage, or service an existing policy, we share the relevant information (such as census or business details) with the carriers and administrators you're requesting quotes from.
• Service providers: we use third-party service providers to operate the Site and run our business, including GoHighLevel/LeadConnector (our website, forms, and customer relationship management platform), Calendly (appointment scheduling), and Cloudflare (bot and spam protection). These providers process personal information on our behalf and are contractually restricted from using it for their own purposes.
• Legal and regulatory requirements: we may disclose information where required by law, regulation, court order, or to a regulator such as the Insurance Council of British Columbia or the Alberta Insurance Council.
• Business transitions: if Sterling Benefits' business is transferred (for example, through a sale or succession), personal information may be transferred as part of that transaction, subject to this Policy or a materially similar one.

4. Cross-Border Data Storage

Some of our service providers, including GoHighLevel/LeadConnector, may store or process personal information on servers located outside Canada, including in the United States. When information is stored or processed outside Canada, it may be accessible to the courts, law enforcement, and national security authorities of that jurisdiction under its laws. By using the Site and submitting your information, you acknowledge this cross-border processing.

5. Cookies and Similar Technologies

Our Site itself does not set first-party advertising or analytics cookies. However, forms and scheduling tools embedded on our Site (provided by GoHighLevel/LeadConnector, Calendly, and Cloudflare) may set their own cookies or use similar technologies as part of their normal operation, such as maintaining your session, protecting against spam, and enabling appointment booking. These third parties' use of cookies is governed by their own privacy policies, which we encourage you to review.

6. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Policy, including to service your inquiry or policy, meet insurance industry record-keeping obligations, and comply with legal requirements. Documents uploaded for a plan comparison are used solely for that review and are deleted upon request or once no longer needed for that purpose. When personal information is no longer required, we take reasonable steps to securely destroy or anonymize it.

7. How We Protect Your Information

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or loss, appropriate to the sensitivity of the information involved. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Rights and Choices

Subject to applicable law, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete personal information;
• Withdraw consent to our collection, use, or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice (withdrawing consent may limit our ability to provide certain services, such as preparing a quote);
• Ask questions about our privacy practices or file a complaint.

To exercise any of these rights, contact us using the details in Section 11 below. If you're not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada, or, depending on your province, the Office of the Information and Privacy Commissioner for British Columbia or the Information and Privacy Commissioner of Alberta.

9. Children's Privacy

Our Site and services are directed at business owners and adults seeking group benefits information, and are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or operational reasons. We'll post the updated version on this page with a revised "last updated" date. Your continued use of the Site after a change takes effect constitutes acceptance of the revised Policy.

11. Contact Us

If you have questions about this Privacy Policy or how we handle your personal information, or if you'd like to exercise any of your rights, please contact:

Ralph Gardner, Sterling Benefits
Email: [email protected]
Kelowna, British Columbia, Canada