Privacy Policy
Our commitment to your data privacy.
Last updated : February 2025
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By entrusting us with your personal data, we are building a relationship of trust together because we want to prove ourselves worthy.
Your personal data is therefore our top priority.
XN Financial® (hereinafter “XN Financial”), comprises the following entities: XN Financial Services Inc., XN Financial Services (Canada) Inc., and is operated for your personal use and information. XN Financial strives to protect your personal data and we have committed to ensuring the best level of security and privacy, notably in compliance with the General Data Protection Regulation No. 2016/679 (the “GDPR”) and with applicable Canadian Privacy Laws (all together “Data Protection Regulations”).
Our personal data processing policy is based on the following six principles:
- Lawfulness of processing: personal data collection and processing are legitimate and based on a legal basis identified in accordance with the objective (or purpose) and the context in which it is processed.
- Purpose of processing: we do not use your personal data for any other purpose. We collect your personal data strictly for the defined purposes.
- Period for keeping personal data: we establish a limited period for keeping your personal data, in accordance with the purposes and lawfulness of processing.
- Security and privacy: We strive to protect and secure your personal data. We take whatever measures needed to ensure a level of security appropriate to the risk between the controller and the processor. In assessing the appropriate level of security, we take into account the risks of each type of processing (sensitive data, purpose of processing).
- Transparency: When we collect your personal data, we will tell you how we intend to use it and if we need to share it with other parties.
- Individuals’ rights: You shall have the right to obtain from us confirmation of your personal data and, where appropriate, the right to correct them. Where applicable, you can request the erasure, portability, restriction of processing or to object to this processing. You can also withdraw your consent at any time, and access to your personal data. For more information, please see the ‘’Your rights as Concerned Person’’ section below.
You can find our obligations and your rights in the General Terms and Conditions of Use on our website as well as in the Privacy policy.
These documents explain how we process, notably, collect, use and store your personal data.
The purpose of this XN Financial Privacy Policy is to inform you about the collection, processing and use of your personal data, and the rights you have in connection with the use of the websites and online platforms, the subscription and the servicing of insurance policies designed, distributed and/or managed by XN Financial.
XN Financial reserves the right to modify this Privacy Policy at any time, due to changes to its websites and online platforms, configuration changes, changes within XN Financial or regulatory changes, or for any other legitimate reason.
1. DEFINITIONS
For the purposes of this Privacy Policy, the following terms – whether capitalized or not – will have the following meanings:
Insured Party: the physical person to whom the coverages of an insurance policy apply (whether or not the said person is the subscriber), the said policy being designed, distributed and/or managed by XN Financial.
Personal Data or Personal Information: means any information which relates to a person and allows that person to be identified either directly or indirectly. This information may include, but is not limited to, your name, mailing address, e-mail address and telephone number. Personal Information does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information. Personal Information can be sensitive (“Sensitive Information”) if, due to its nature, in particular its medical, biometric or otherwise intimate nature, or the context of its use or communication, it entails a high level of reasonable expectation of privacy. Under the GDPR, Sensitive Information is Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
Concerned Person: refers to an identified or identifiable physical person; is deemed to be an “identifiable physical person”, i.e. a physical person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that physical person.
Personalized Space: means a space on a Site accessible to Insured Parties under the conditions provided for in the General Terms and Conditions of Use of the Site and by means of a username and a password.
Controller: means the physical person or legal entity, the public authority, the service or whatever other body that, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
Services: refers to the XN Financial services for brokers and companies as well as the Site.
Site: refers to the XN Financial website accessible at http://xn.com and online platforms, including public spaces accessible to all Users, and Personalized Spaces through which XN Financial provides Insured Parties with services under the terms of insurance policies designed, managed and/or distributed by XN Financial. The Sites, including the Personalized Spaces, are subject to the General Terms and Conditions of Use (CGU) which this Privacy Policy supplements.
Processing or Process: means any operation or set of operations performed using processes that may or may not be automated, applied to personal data or sets of personal data, such as the collection, recording, structuring, storage, adaptation or alteration, retrieval, consultation, use, or disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2. YOUR CONSENT TO COLLECTION, USE AND DISCLOSURE
XN collects, uses, discloses and retains personal information that you provide to us with your consent.
3. PERSONAL DATA PROTECTION
3.1 Identity and Contact Details of the Controller
Personal Data is collected and processed by:
XN Worldwide Insurance – Canada Montréal
2310-600 De Maisonneuve Ouest
Montréal, QC, Canada H3A 3J2
3.2 Contact Details of the Privacy Officer
XN Global Health Insurance has appointed a Privacy Officer who can be contacted at:
Privacy Officer
XN Global Health Insurance
14 Boulevard du Général Leclerc
92 200 Neuilly-sur-Seine, France
privacy@xn.com
3.3 Collection Methods
When you visit our site, we collect some personal information about you.
3.4 Purposes and Legal Basis of Data Processing
We process your personal data to provide and improve our services to you. We also use it to meet our legal obligations.
3.5 Mandatory/Optional Nature of the Collection
XN Financial informs you when the provision of an information item is mandatory (including when due to a legal, regulatory or contractual obligation, or simply in order to process your request or respond to you). If you do not provide this so-called “mandatory” information, XN Financial may be unable to respond to the request or form in question or to provide the Services.
Fields on a form that are not specified as mandatory are left to your discretion. It is up to you to choose to whether to fill them in or not.
3.6 Data Recipients
We may provide your personal data to our service providers and partners to provide our services.
3.7 Location of your personal data
Your personal data is currently hosted in Canada and can be transferred to third parties outside of your country/state/province of residence.
3.8 Data Stored Period
We will only keep personal information for as long as reasonably necessary to fulfill the relevant purposes set out in this Policy Privacy and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which personal information will be kept, please contact us at privacy@xn.com.
3.9 Opting Out of Communications
If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us, you may log-in to your account and make changes to your communication preferences. You may also opt out by contacting us directly.
We endeavor to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.
3.10 Your Rights as Concerned Person
You also have the possibility of filing a complaint with the relevant data protection authority.
We will take steps to ensure that your Personal Information is kept as accurate, complete and up-to-date as reasonably necessary. We will not routinely update your Personal Information, unless such a process is necessary.
To make sure that the information we hold on you is accurate and up to date, please inform us promptly of any change in your Personal Information.
On written request and subject to proof of identity, you may consult the Personal Information that we have collected about you, and ask that any necessary corrections be made, where applicable, as authorized or required by law. The information required to identify you will only be used for this particular purpose.
In addition, under certain circumstances, you have the following rights:
If you want to learn more about your rights under the GDPR, you can visit the European Commission's page on Data Protection at: European Commission - Rights for citizens.
You also have the right to lodge a complaint with the relevant data protection authority.
You also have the possibility of filing a complaint with the relevant data protection authority.
3.11 Automated Decision-Taking
In the event of non-payment of the Insured Party’s premiums, the follow-up, notice and delisting procedure is automated.
Since this processing gives rise to an automated individual decision, you have the following rights under the terms of the applicable Data Protection Regulations:
- The right to request the involvement of a person to verify the Processing in question and ensure the compliance of the decision applied to your situation;
- The right to challenge a decision taken automatically by XN Financial systems, by sending your request to your usual contact at your management unit (MU) or the XN Financial Complaints Department, at the following address: privacy@xn.com
3.12 Data Security and Privacy
4. COOKIES AND OTHER MEANS OF TRACKING
We may also collect and Process Information about your visit to this website, such as the pages you visit, the website you came from and the searches you perform. We may use such information to help improve the contents of the site and to compile aggregate statistics about people using our site for our internal usage statistics and market research purposes.
In doing this, we may install "cookies" or similar technologies that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. Cookies are created and stored on the user's computer, phone or other devices when the user's browser loads a particular website. Every time the user goes back to the same website, the browser retrieves and sends this "cookie" file to the website. Cookies are useful because they serve key purposes like helping a website remember your preferences and settings, performing analytics to improve services, serving you relevant content or advertisements and authenticating you on the websites. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie, this will enable you to decide if you want to accept it or not. You can also refuse cookies altogether. However, if you do not accept our cookies, you may not be able to use all functionalities of our website. When you visit our websites, you may be presented with a cookie-setting banner that allows you to manage the settings and accept or deny the cookies. It is legally permitted to store cookies on your machine if they are essential to the operation of the website, but for all other types of cookies we need your permission to do so. You have the option to consent to the use of cookies while visiting the website for the first time when a cookie banner will be shown or manage these settings anytime later by clicking the Cookie Settings link in the footer of the website. These cookie settings give you the option of accepting or denying your consent to every category of cookies (with the exception of the necessary cookies which are always active). Please refer to our Cookie Settings to learn more about what types of cookies we use (the purpose they serve, their lifespan, and their provenance) and how you can manage your preferences.
5. WHEN DOES THIS POLICY NOT APPLY?
Do take note that if you access any third-party link or website from our Services, you may need to refer to the privacy policies of such third parties. XN does not endorse and is not responsible for the information or privacy practices of websites or services owned by third parties.
6. CONTACT US
If you wish to contact us regarding how we use your Personal Data or you wish to exercise your data privacy rights, please email our Privacy Officer at:
Privacy Officer: privacy@xn.com