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Alan - Privacy Policy
Alan - Privacy Policy
A privacy policy is often a big, intimidating block of text that is supposed to reassure you but that you don't read.
We have written ours to be as clear and accessible as possible, so that you understand exactly how your personal data is used by Alan.
Enjoy your reading.
Table of contents
In the course of its activity as a health insurer and as a health management services provider, Alan is required to process sensitive personal data. We attach the utmost importance to the security and confidentiality of the data of Alan's services’ users, whether on the alan.com website or on the mobile application made available to them.
The purpose of this privacy policy is to help you understand how we treat the personal data you provide us with, in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and, where applicable, provincial privacy laws.
This privacy policy may be updated regularly, to enrich it, according to Alan's needs, circumstances or if required by law. We therefore invite you to check for updates on a regular basis, although we will always notify you of any significant changes affecting the way your data is processed.
Version dated February 18th 2026
Above all, we have set ourselves two key principles which are also included in our contracts:
- Alan will never sell the data collected about its members in connection with the services offered. We make our living by building and managing insurance products and services around health, not by reselling our users' data. Users remain in control of their data.
- As a health insurer, Alan will never use health data to apply differentiated rates based on a member's situation or history. We strongly believe in the strength of solidarity and risk sharing between insured members.
Furthermore, in accordance with the regulations and particularly the PIPEDA and GDPR, we undertake to collect and process only the data that is strictly necessary for their purpose. Similarly, we undertake to ensure that the data collected is kept in a form that allows your identification for a period that does not exceed the time required for the purposes for which the data is collected and processed.
Alan requires your consent to collect, use, or disclose your personal data, except under the exceptions permitted by law. Please note that your consent may be either expressed (verbal or written) or implied (inferred from your actions).
You have the right to withdraw your consent at any time, subject to our legal, regulatory, or contractual obligations. However, this may limit your access to some of our services and products. To withdraw your consent, please contact our Data Protection Officer (DPO), the contact details are in the section below.
If you have any questions regarding security and personal data, or to exercise your rights of access, correction, deletion, withdrawal of consent, limitation of processing, opposition to processing or portability, you may contact us and our Data Protection Officer (DPO) at [email protected]. Alan will ensure that you receive a response promptly.
For any complaint concerning your personal data, you can either contact our DPO or contact:
For Canadian residents: the Office of the Privacy Commissioner of Canada directly at:
Office of the Privacy Commissioner of Canada
- 30 Victoria Street
- Gatineau, Québec
- K1A 1H3
- Telephone: 1-819-994-5444
- Toll Free: 1-800-282-1376
- Website: www.priv.gc.ca
For Ontario residents, you can also contact the Information and Privacy Commissioner of Ontario at:
- Information and Privacy Commissioner of Ontario
- 2 Bloor Street East, Suite 1400
- Toronto, Ontario M4W 1A8
- Telephone: 1-416-326-3333
- Toll Free: 1-800-387-0073
- Website:www.ipc.on.ca
For Québec residents, you can also contact the Commission d’accès à l’information du Québec at:
- Commission d’accès à l’information du Québec 525 René-Lévesque Blvd East, Suite 2.36 Québec, Quebec G1R 5S9 Phone: 418-528-7741 Toll-free: 1-888-528-7741 Website: www.cai.gouv.qc.ca
Insurance Services
Care and support
Health Services
Statistics and Performances
This data is used for the electronic signature of the contract, any communication with the company's representatives, and for access to the account used to manage the contract. In the case of delegated contracts, this data is also received from the contract insurer.
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, the usual retention periods are as follows:
- 5 years after the end of the contract for health insurance contracts
- 10 years after the end of the contract for life and disability insurance contracts
- 2 years after the last connection if the contract has not been signed
From the Alan dashboard.
Only if the contract has not been signed. Otherwise we are required to keep the data.
Employees
The company contract administrators are led to send us data concerning their employees, including those who have left the company for less than a year ( as part of the portability of health insurance rights):
- Name, surname and social security number
- Employees' professional email address
- Personal e-mail address of former employees
- Dates of arrival and departure from the company
- Birth date
- Gender
- Salary and occupation where applicable
This is a legal obligation of the employer from which employees cannot escape, even when they do not wish to benefit from health coverage (exemption mechanism).
This data is used:
- to obtain quotes and underwrite insurance coverage,
- for the registration of employees on our mobile application.
- 5 years after the end of the contract for health insurance contracts
- 10 years after the end of the contract for life and disability insurance contracts
- 2 years after the last connection if the contract has not been signed
Contract administrators can do this directly from their Alan dashboard. In some cases, an intervention of our customer service is necessary (for example for certain retroactive modifications).
No, Alan has to keep this data.
Health and life and disability insurance
Personal data is transmitted to us directly by or on behalf of the insured members with their explicit consent (e.g. to automate the retrieval of receipts from a third party site), in particular :
- Name and surname
- Personal email address
- Birth date
- Postal address
- Name, surname, birth date and gender of the spouse and/or children where applicable
- Bank details (for payments and reimbursements)
- Documents required for reimbursement of care acts
- Messages to our customer service department
- Data necessary for the reimbursement (date of treatment, act code, amount paid, recognized rights, prescription, Drug Identification Number, etc.)
- Other insurance plan information (if any, for coordination of benefits)
- Proof of good health, if applicable
- Proof of exemption where applicable
- Life insurance beneficiary information (including names, relationship to insured, date of birth, and contact information)
We also generate individual policy numbers.
We use this data mainly to process requests for reimbursement of expenses according to the guarantees of the contract which covers the insured members and any declared beneficiaries. In particular, this involves receiving and processing the health documents and information provided to justify the care received, determine coverage, generate payments and manage the recovery of undue payments. They are also used for :
- the execution of legal, regulatory and administrative provisions
- management of complaints and disputes
- the prevention of money laundering and the financing of terrorism
- the drawing of statistics and actuarial studies, the development and management of insurance products
- management of financial aspects, performance and risk
- management of Alan's websites and applications (including bug and error management)
- customer relationship management and service improvement
- user research and surveys
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, the usual retention periods are as follow:
- 5 years after the end of the contract for health insurance contracts,
- 10 years after the end of the contract for life and disability insurance contracts.
No, because we are obliged to keep this data. However, you have the possibility to ask us not to use them for purposes other than the performance of your insurance contract and compliance with our legal and regulatory obligations, by sending an email to [email protected].
Dependent data
I have been added as a dependent
When the possibility is offered to him/her and an insured member declares a dependent (spouse or child) to his/her contract, he/she vouches that the beneficiary agrees to become a party to its insurance contract (or gives consent as a parent of a minor). Alan treats the personal data of the dependent in the same way as those of any other user insured member in this capacity.
Account sharing
Our insured members and their dependents share a single Alan account. By default, both the insured members and the dependents (if they are of legal age and choose to access Alan's online insurance or management services themselves) will be able to view all account information related to the insurance services, without separation. Members with an Alan account can also choose to restrict visibility of their care acts to other members covered under the same policy.
How can I have access to this privacy setting?
Through the "Privacy and security" section on your member profile.
Fraud fighting
We use personal data you provide us with in the context of our health insurance (including your health data) in order to detect and fight insurance fraud. We may also use the following connexion data to identify fraudulent behavior:
- IP address and service provider,
- information about your equipment, for example: type of internet connection, type of device used, browser used and version, etc.
We use this data for the prevention of fraud, in particular to detext suspicious patterns or activities and to manage alerts and procedures following a case of fraud.
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, the usual retention periods are as follows:
- 6 months from the issuance of the fraud alert.
- 5 years from the closure of the fraud case if the fraud alert is considered relevant.
Data you provide us in the context of your health insurance serves multiple purposes. If there is a specific reason you would like to oppose Alan processing your personal data for the purpose of fraud fighting, you can send an email to [email protected], we will consider your request and balance your rights with Alan’s legitimate interest.
This data is used to authenticate members in order to provide them with travel assistance abroad.
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, we keep this data 5 years after the end of the contract.
No, Alan must keep it for 5 years after the end of the coverage.
Messages and chat
In order to answer questions or resolve problems raised by our members, admins or prospects when they contact Alan we collect the following information:
- Messages and attachments sent to our customer service;
- Voice notes;
- Any data related to your insurance contract required to answer your question or resolve your problem;
- Customer satisfaction surveys.
We may thus collect the following personal data:
- identification data,
- financial or payment data,
- health data.
We use your data to analyze and answer your questions, provide guidance, manage complaints and disputes, and improve our services and products. In order to do so we:
- automatically classify your message to assign the most relevant agent to meet your needs;
- provide you immediate automatically generated answers when possible;
- review your message and our responses to ensure the quality of our service;
- use your message to keep track of your instructions.
In addition, your data will also be anonymized to enable research and statistical learning.
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, the usual retention periods are as follows:
- 5 years after the end of the contract for health insurance contracts
- 10 years after the end of the contract for prévoyance contracts
- 2 years after the last connection if the contract has not been signed
- 90 days for voice recordings.
We are obliged to keep the data relating to your insurance contract and demonstrating legal compliance. However, you can request the deletion of other data collected by emailing [email protected].
To speak to therapist or social worker by video or phone
When you book or attend a session, we collect information needed to schedule, deliver, and administer the service, such as:
- your first and last name,
- the date, time, and duration of the session,
- your time zone,
- your province/territory and language preference,
- the practitioner’s name and professional details.
In some cases, we may also collect intake information you provide (for example, questionnaire responses) to support your care.
We do not record your calls. However, during your care, the practitioner may create clinical notes (for example, session notes or care summaries).
Depending on how the practitioner works, notes may be:
- entered into Alan’s platform,
- written separately by the practitioner.
Where clinical notes and intake forms are stored in Alan’s platform:
- access is restricted to authorized clinicians involved in your care,
- Alan applies technical and organizational safeguards, including encryption and access controls, designed to protect confidentiality,
- this information is not used for insurance administration or reimbursement decisions.
For orientation call, if the member accepts, orientation psychologist will share the reason for consultation and situation with the psychologist booked. This information is deleted once shared.
Note that the Alan attributed e-mail address of the Practitioner is solely for communicating on administrative matters with you and/or your employer. This emailing address shall not contain any health related information.
To facilitate scheduling and coordination, we also process the practitioner’s identifying and professional data, as well as their calendar availability.
We use this information to:
- schedule and enable sessions with our practitioners,
- improve the service.
For no longer than necessary for the purposes described above, including to meet applicable legal and professional record‑keeping requirements.
Yes, you can send a request to [email protected]. However, we may not be able to delete data that must be kept to comply with legal or professional record‑keeping requirements.
To speak to the Alan health team by private message within the Alan Clinic
When you exchange messages with Alan health team members for a question relating to your health (excluding video consultation), we use the following data:
- first name, surname, date of birth, and gender (that we deduce from your insurance profile),
- phone number for emergency situation,
- messages and attachments exchanged with the health team member.
To delivered more personalized and contextualized care to members, health team members will also have access to:
- your company's vertical, the number of employees, and your start date with the company,
- the gender and age of your children beneficiaries,
- your city of residence,
- some usage data of our health services.
Your messages and clinical information are accessible only to health professional of the Clinic involved in providing care, and to a limited set of authorized personnel as needed to operate and secure the Clinic (for example, to maintain the platform). We use role‑based access controls and other safeguards to protect confidentiality. Your health information is not used for insurance purposes.
We use this information to:
- enable secure messaging between you and the health team members,
- provide access to your message history,
- enable research and statistical learning on non-identifying data after anonymization.
Alan respects medical secrecy: the content of your exchanges within the Alan Clinic is accessible only to members of the Alan medical team, they many not be consulted or used by anyone else at Alan.
In addition, when you have had an inspiring health experience with the Alan Clinic, we may contact you to create a fully anonymized educational health story for the benefit of as many people as possible. These health stories will only be created with your prior and specific consent, and in a non-identifying manner.
We retain messages and related records for as long as necessary to provide the service and to meet applicable legal and professional record‑keeping requirements.
You can request the erasure of messages from your interface, simply send a request to [email protected]. However, we we may need to keep a secure archived copy where required for legal, regulatory, or professional obligations.
We use the NPS to monitor our performance with our members, through the Metabase tool. In concrete terms, this allows us to identify factors of dissatisfaction that may allow us to improve our services or, conversely, things that need to be reinforced because they are highly appreciated.
We keep them for the time needed to carry out analyses and measure their evolution over several development cycles. We then anonymise or delete them.
Yes, simply send a request to [email protected].
Audience measurement (analytics) and technical data
Certain data is collected automatically when you visit alan.com (including other websites published by Alan such as blog.alan.com and map.alan.com) and when you use our mobile app. The data collected includes :
- IP address and service provider;
- user ID;
- information about your equipment, for example: type of internet connection, type of device used, browser used and version, etc;
- time stamp information and length of visit;
- pages visited;
- clicks and other interactions on individual pages;
- possible errors (on the browser, the mobile application or our servers).
This data is used for the following purposes:
- to comply with legal, regulatory and administrative provisions (connection logs, etc.);
- customer knowledge and customer relationship management;
- operations relating to canvassing and the compilation of commercial statistics;
- identification of customers or prospects to improve service by offering products or services to reduce the number of claims, or to offer a complementary contract or a service;
- analysing the use made of the product and improving the product;
- management of people's opinions on products, services or content.
The data is kept only for the duration necessary to achieve the purposes. Unless otherwise required by law or regulation, the usual retention periods are as follows:
- 2 years
- 3 years for data relating to prospects
- 13 months for cookies
Absolutely (with the exception of data collected in the framework of a legal obligation or strictly required to provide our services), simply make a request to [email protected].
Marketing and Ad targeting
To build our audience and client basis, Alan may reach out to prospects by emails and organize online advertising campaigns before sending them mails or emails. In this context, Alan handles email addresses available online (such as on Linkedin) but also from providers already used by Alan (Societeinfo.com, Kaspr) for audience-building purposes on social networks.
We are reaching prospects via online ads before sending mails or emails. To do so, we import prospects database into the audience of different platforms. The email addresses is the only data import on the ads platform. We import only prospect data and we do not bring in any customer data or leads who have unsubscribed from any previous campagin. To do so, we ensure and remove our customers data in our ads audience before any data import. In addition, users can opt-out and unsubscride from seeing Alan’s ads directly on the ads platform.
When reaching out by email, Alan provides easy-way to opt-out notably through unsubscription links in each communication and honor prospects opt-out in the future.
We keep this data for 2 years, in line with CNIL’s recommendation.
A purge of the database to remove any inaccurate is carried out on a monthly basis.
Yes, you can opt-out from marketing communications at any time. You can exercise any of your rights simply in making a request to [email protected].
Statistics and scientific research
Data collected by Alan in the performance of our services, may be further used in a way compatible with the original purpose for which it was collected. Only aggregated and/or anonymized data may become subject to scientific research and/or for statistical studies, including for statistical learning. It could for instance be used in the selection and creation of relevant health stories to improve our services and Members' health, create aggregated usage reports or to streamline and improve the management of exchanges with Alan medical team.
Data security is an extremely important issue for Alan: we do our utmost to be worthy of the trust you place in us. Here are a few examples of the measures we have taken. If you have any questions on a specific point, we will be happy to answer them at [email protected].
Alan achieved ISO27001:2022 certification with SGS (certification body), validating our information security management system and our data protection measures. This certification covers all of Alan’s activities.
We use Datadog App Security to detect and block in real time attacks such as XSS, SQL injection, account theft, etc.
We also use Cloudflare to protect us from Distributed Denial of Service (DDoS) attacks.
All HTTP traffic to and from alan.com and api.alan.com is encrypted (HTTPS / TLS). You can evaluate our configuration here.
The first time a user logs on, we tell their browser (via the HSTS mechanism) that all subsequent connections must be encrypted (HTTPS), including when a link to alan.com starts with http:// instead of https://.
When using the Alan Clinic services, your questions to our medical team, answers and attached documents are secured by an additional layer of application encryption entirely and exclusively under the control of our medical team. No one other than the Alan medical team is technically able to consult these exchanges.
For data hosting and processing, Alan uses AWS, which is HDS-certified. Our entire infrastructure is located in the Frankfurt region, in Germany. In order to fulfill all the purposes for which we collect your data, we may transfer some of your data to third parties, who host it in data centers located within and outside the European Union. When data is hosted outside the European Union, we make sure that hosting is subject to European data protection standards (for example, by including standard contractual clauses in our contracts with such third parties). You can find more information on data privacy with AWS security here, and our blog post on the subject here.
We use PostgreSQL databases. The data is encrypted using the AES-256 standard and the encryption keys are managed by AWS.
The backup archives are also encrypted.
We use the open-source zxcvbn-ts library to let users know the strength of the password they choose. The minimum size is 16 characters, including alphanumerical characters and symbols, and the minimum score is 4.
We do not store these passwords: we only store a non-reversible hash calculated by the open-source bcrypt library, with the following parameters :
- a cost of 12 (i.e. 4096 iterations) to limit brute force type attacks
- one random salt per user to protect against rainbow tables
All Alan employees receive mandatory training in security (including social engineering) and data privacy. They use complex and unique passwords and strong authentication (2FA) whenever possible. The use of a password manager such as 1Password is also mandatory.
Our computers are automatically updated and have their hard disk encrypted (in case of theft). Our screens lock automatically.
Access to our internal administration tools requires individual access from an authorised IP address and all data modifications (by an Alan employee or by a user himself) are audited.
We organise intrusion tests by independent companies.
All Alan services and applications are developed in-house. Our code is validated by automated tools (static analysis, security, etc.) and manually by a second pair of eyes.
In order to protect your data on your computer or mobile phone, you can take a few simple measures:
- apply regular system updates to benefit from security patches;
- use antivirus software to detect the presence of malware or spyware, or to disable security features;
- protect your passwords well (your Alan account password, your mailbox password...);
- enable Privacy mode in the mobile application. You will then be prompted for biometric authentication (Face ID/TouchID) or a PIN every time you open the application;
- enable two-step authentication in the mobile application. After entering your email and password at login, you will receive an email with a unique code to enter the application.
You can also consult the official recommendations on good IT security practices.
Who else besides Alan has access to my data?
The data collected may be communicated as required to Alan's partners, reinsurers, subcontractors, legal and financial advisors, and service providers. These data transfers are carried out solely within the framework of the operations mentioned above and to the extent necessary for the performance of the tasks we entrust to third parties. These third parties are fully informed by Alan of the confidentiality of the data communicated to them in this context, and these partners have an obligation to ensure the protection of this data. They are also bound by their own confidentiality and privacy policies, which can be consulted on their websites. When the nature of the operation carried out allows it, the data is subject to prior anonymisation before being communicated to third parties.
The main persons and tools that receive the data in the context of our processing operations include:
Insurance data
Amazon Web Services (hosting and storage) Stripe.com (payment) Revolut.com (refunds) Intercom.com (online chat and customer service) Google Vision (document recognition) Sendgrid.com (emails) Sentry (error management) Linear (ticket management) Customer.Io (emails) Hubspot (CRM) Outreach (CRM) Salesforce (CRM) Snowflake Datadog Scale Studio (document annotation) Microsoft Azure (Azure OpenAI for document parsing) Xodus (travel insurance partner) OmbudService for Life & Health Insurance or the Financial Services Regulatory Authority of Ontario (external review of complaints) Telus (claims processing) Northbridge (travel insurance) Programmed Insurance Brokers (life & disability insurance) RWAM Insurance Inc. (life & disability insurance)
Audience and usage measurement data
Segment.com (audience analysis) Amplitude.com (audience analysis) Google Ads (targeted advertising) Google Optimize (AB testing) Google Speech-To-Text (voice recognition) Google Calendar (calendar) Meta Pixel (audience analysis and targeted advertising) X Ads (targeted advertising) LinkedIn Insights (targeted advertising) Customer.io (e-mails) Bing (audience analysis and targeted advertising) Datadog App Security (security) Cloudflare.com (network, security and audience analysis) Hubspot (Audience analysis and CRM) Piwik (audience analysis) Hotjar (user survey and navigation analysis) Calendly (scheduling tool for meetings)
Furthermore, in order to meet legal and regulatory obligations, we may be required to communicate personal information to administrative or judicial authorities at their request. In this case, we ensure that only the data strictly required by the authorities is transmitted.
In order to fulfill all the purposes for which we collect your data, we may transfer some of your data to third parties, who host them in data centers located in:
- the European Union (Alan AWS infrastructure in Germany)
- other Canadian provinces (partners and service providers)
- the United States (certain service providers)
In this case, we ensure that the hosting is subject to applicable data protection standards:
- Before communicating your personal data outside your province, Alan carries out a privacy impact assessment and takes protective measures.
- All these transfers are governed by contracts including personal data protection clauses as well as appropriate security measures for the communicated data.
To obtain more information about our data transfer practices, please contact our data protection officer at [email protected].
What's a cookie?
In addition to being a delicious biscuit, a cookie is a file on your device that contains data. We obtain your consent before using cookies where it is required. You can delete or limit the storage of these files at any time in the settings of your internet browser (see below).
What's it for?
- First of all to identify yourself once you are connected to the application.
- Technical cookies ensure the proper functioning of our website by managing essential features like security and remembering your preferences (such as language settings).
- Functional cookies help us personalize your experience, save information you've entered, remember your navigation choices, and maintain your session data so you don't have to re-enter information as you move through our website.
- Some cookies also allow us to reply to you in the online chat, in the window that opens at the bottom of your screen when you visit our website.
- Performance cookies help us detect and resolve technical issues to ensure our website runs smoothly.
- Audience measurement cookies enable us to know the use and performance of our website, to establish statistics, traffic volumes and use of the various elements of our website (content visited, paths) enabling us to improve the interest and ergonomics of our services. The data collected is analysed solely by Alan and its subcontractors, and used solely by Alan.
- Cookies linked to targeted advertising operations enable us to measure the effectiveness of our advertising campaigns and to limit the number of times an advertisement for Alan is offered to you. None of these advertising cookies are used by Alan when members are authenticated.
- Consent management cookies remember your cookie preferences so we don't repeatedly ask for your consent during subsequent visits to our website.
What are the third-party cookies used on our website?
Third-party cookies used only on our public website based on user choice:
- Google Ads (targeted advertising) - you can find more information about Google's data processing through this link.
- Meta Pixel (audience measurement and targeted advertising)
- X Ads (targeted advertising)
- LinkedIn Insights (targeted advertising)
- Bing (audience measurement and targeted advertising)
- Hubspot (audience measurement and CRM)
- Piwik (audience measurement)
- Hotjar (user surveys and browsing analysis)
- Posthog (audience measurement, user survey, A/B tests)
- Affilae (affiliate program)
- Tally (technical cookie forms)
Third-party cookies used on our public website and dashboard (member and administrator) based on user choice:
- Segment.com (audience measurement)
- Amplitude.com (audience measurement)
- Snowflake (audience measurement)
In full transparency
You can find more information about the data collected by Alan via these third-party cookies through this link.
Can I refuse?
Of course you can! During your first visit (or if you use your browser's private or incognito browsing), a banner (called a cookie banner) will be displayed asking you for permission to use cookies. Simply refuse and no cookies (other than those we need to operate the site and allow you to use our online chat) will be set. If you accept, your consent will be valid for 13 months from the date of registration.
Simply put, no.
You will receive emails from us, but in the vast majority of cases it will be in the context of the execution of our contract, for example to invite you to register, to ask you for additional information to enable a refund or to inform you of contractual modifications or changes related to your account. There is no escaping this, but it is for your own good.
A small minority of emails are not directly related to our contract with you or your employer, but are still for a legitimate interest (e.g. to offer to sponsor a relative with a financial reward, to send you a quote, or to announce new services similar to those you currently enjoy).
If you are an administrator, you may also receive commercial offers from us. In these cases, you always have the possibility of unsubscribing from this type of message by following the link in each of our emails (opt-out).
You can also choose to subscribe to our newsletter or to our waiting lists to be notified of the availability of our new services (opt-in).
As for push notifications, we will ask for your permission directly in the mobile application and you will be able to deactivate or reactivate them from your phone.
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