Privacy Protection Policy

Client information is private and confidential. Introduction Capital Inc. (IC) recognizes that clients have a right to have their information protected. 

IC’s Privacy Protection Policy governs the collection, use and disclosure of personal client information. Specifically, this policy outlines how IC complies with provincial and federal regulations governing client information including the Privacy Act and the Personal Information Protection and Electronic Document Act (PIPEDA).

PIPEDA is the Canadian federal privacy legislation established in January 2004. Under PIPEDA no business may collect, use or disclose personal client information without clearly defining the purpose of such collection, use or disclosure and obtaining informed consent. The collection, use or disclosure is limited to purposes that a reasonable person would consider appropriate in the circumstances. The legislation further regulates the protection, retention and destruction of client information. PIPEDA offers clients the right to access their information upon request and challenge the information that is being retained.

The key privacy principles of PIPEDA form the basis of IC’s comprehensive Privacy Protection Policy.

It is important to safeguard private and confidential client information. IC confirms compliance with privacy legislation and uses the utmost discretion when dealing with client information. IC will regularly monitor and assess the environment of compliance in terms of protection of private client information.

Client information is any information that identifies an individual including such items as: an individual’s name, address, age, financial information, social insurance number, personal email address and telephone numbers. Client information may be in paper or electronic form.

IC will collect and retain client information for a number of purposes including to: determine a client’s identity, provide services to clients, administer client accounts, establish and manage relationships (including conducting client evaluations and assessments), provide client communications and other commercial reasons.

IC will use client information only for the purposes identified at or before the time of collection.  IC does not sell or rent client information – under any circumstances. IC does not transfer collected information to competitors.

All information concerning clients and their accounts are confidential and will not be disclosed to unless the intended purpose is disclosed.  Should client information be required for a new purpose, IC will take the necessary steps in order to seek additional consent.

Consent may be expressed in writing, orally or implied directly by the client. In most cases consent is obtained via provision of business cards, written agreement, applications, registration to events and/or by attendance. All client information collected by IC will be kept confidential and shall not be disclosed to any third party, except for the specific reasons expressly identified or if the client has provided express consent.

From time to time, requests for client information may be received from: government agencies; law enforcement agencies; securities commissions; law societies; other self-regulatory organizations (SRO’s); or under a court order. Express consent will not be required if needed for: audit, statistical or record-keeping purposes; a legal reason or request by securities or legal regulatory authorities or SRO; to collect a debt owed by the client; to a legal professional for the purposes of obtaining legal advice; and pursuant to a court order. Should IC be asked to produce confidential information by any such entity, IC will comply. In some cases, IC may provide information on its own initiative if there are reasonable grounds to believe crime or a violation of applicable regulation is involved.

Consent to use personal information may be withdrawn by a client at any time.

Client information will only be collected as needed for intended purposes.

During the course of providing products or services to client, IC may collect personal information in several different ways: the website, by telephone, by written correspondence, or by e-mail. The purpose of collection of personal information is for the sole purpose of providing services and in order to adequately communicate information.

IC does not collect specific client information from site visitors unless personal information is provided or contact is requested.  If information is provided, it will be collected for the purpose of answering inquiries, providing marketing materials, corporate background and to invite guests to access services and/or events.

IC’s website may employ standard technology to collect information about how the firm’s site is used for the purposes of improving website design. Website information is collected in many forms including by obtaining the domain name of visitors, user preferences, personal information that is volunteered, and geographic location.

Website guests may occasionally receive emails from Introduction Capital informing them of events and services.

Client information will only be used for the purposes for which it was collected.

IC may share client information with authorities for regulatory or tax reporting purposes.  Information may also be shared with legal bodies, SROs and other authorities for reasons previously discussed. Client information may also be shared with external service providers or strategic partners/affiliates (upon verbal consent by the client).

Client information will only be retained for as long as needed in order to satisfy the stated purposes at the time of collection. When the information is no longer required necessary measures will be taken to destroy, dispose of, or delete the information.

It is important for IC to keep client information accurate in order to provide quality service and minimize the potential for misuse. IC strives to keep client information correct, complete and up-to-date. Clients may be contacted periodically to ensure information is accurate on file.  Clients are requested to advise IC of any changes to client information, as IC is not liable for errors that cannot be corrected without client input.  Should an inaccuracy be found, IC will act efficiently to correct it at no cost to the client.
Security measures include passwords on networks and systems and restricted access to the office, and records within the office.
IC makes every effort to explain policies and procedures to clients and explain how client information is managed.  IC’s Privacy Protection Policy will be provided upon request by e-mail or phone. Also, a copy can be found on the IC’s site.

Clients have a right to their personal information. Clients have the right to verify the accuracy and completeness of their personal information, and may request that it be amended. Upon request (in writing) with appropriate supporting documentation confirming identity, clients will be given a copy of their client files.

Under certain circumstances IC may not be able to provide clients with access to specific pieces of information. For example, clients will not be granted access to information containing references to other persons or that has proprietary information confidential to the firm. Also, access will not be provided to information that has been destroyed or is too costly to retrieve.

IC will respond to requests for access in writing within 30 days of receipt.

Inquiries and complaints will be reviewed and dealt with in a timely fashion.  Specifics steps of IC’s privacy complaint recourse process are:

  1. All complaints are directed to the Privacy Officer who will maintain a detailed file on the complaint.
  2. The complainant will be notified of receipt of the complaint. All other applicable parties will be provided notice as well.
  3. The Privacy Officer will conduct an investigation to gather all necessary facts pertaining to the complaint.
  4. Following the investigation, the Privacy Officer will make a determination that either no other remedy than a clear explanation to the client is warranted or that the complaint is substantiated and as such, specific action is required. Some examples of specific recourse include implementing additional safeguards, employee training and documentation revision.
  5. The client will be advised of the decision in writing with details of the findings and subsequent recourse action, if any.  Where applicable, a formal apology will be issued by IC or a third party for the mishandling of client information.

Clients who remain dissatisfied with the results can bring the complaint to the attention of the federal Privacy Commissioner who is the ombudsperson for complaints under PIPEDA at:  Officer of the Privacy Commissioner at 112 Kent Street, Place de VilleTower B, 3rd Floor, Ottawa, Ontario K1A 1H3. The request must be made in writing and include full contact details and as much detail as possible about the complaint.

IC’s Privacy Protection Policy is intended to provide clients with comfort that their personal information is handled with the utmost importance and care.  IC is continually balancing clients’ right to privacy with the needs of the business and therefore, welcome any feedback on how privacy protection policies and procedures can be improved.

For more information, please contact the Privacy Officer – Amana Manori, Managing Director and CLO at amana@introcap.com.