We value your business and thank you for your confidence in choosing our firm as your source for advice, insurance and investment products. As our client, you trust us with your personal information. We respect that trust and want you to be aware of our commitment to protect the information you share in the course of doing business with us.
1. The Company: In this Privacy Notice, ITI Financial Inc., is referred to as “the Company”.
2. Client Account and Personal Information: The personal information collected about clients for the purposes identified in this Privacy Notice is held in a record called the “client record”. The personal information in client records may include a client, client’s spouse, children (minors) and client’s business name, address and telephone number, social insurance number, birth date, account, holdings and the name, address and social insurance number of spouses and beneficiaries. Depending on the investment or service requested, additional personal information may be held in the client record. For example, if a client establishes a pre-authorized systematic payment plan, the client’s financial institution account number for such a plan is also held in the client record.
3. How We Collect, Use and Disclose Your Information: To make an investment, to purchase insurance products, to provide instructions to the Company about an investment already made or existing insurance products and/or to receive information related to an investment or insurance product, clients may disclose information to the Company concerning spouse, beneficiaries and/or other family members. The Company collects this personal information, which may include medical information and holds it in the client records. The Company may collect, use and disclose personal client information to third parties to provide to clients, products and services for which the Company is not directly licensed.
This information may include:
a) identifying the client and ensuring the accuracy of information contained in each client record;
b) establishing and administering a client account, determining, maintaining, recording and storing account holdings and transaction information in the client account;
c) executing transactions with or through the Company including transferring funds by electronic or other means;
d) providing a client’s account statement, portfolio reports, tax receipts, financial planning documents, tax returns, financial statements for the investments that have been made, proxy mailings, transaction confirmations and other information which the client or his/her financial advisors or dealers may request as needed to service the client’s account. Existing clients of the Company prior to December 31, 2020 will continue to receive such documentation in the manner previously employed. If another method of delivery is preferred, the client must consent in writing to their financial advisor. All new clients will consent to their preferred method of delivery when their accounts are established;
e) protecting its own business interests including collecting a debt owed to the Company or allowing the performance of transactions;
f) meeting legal and regulatory requirements including its disclosure to regulatory bodies and self-regulatory organizations, and use and disclosure by regulatory bodies and self-regulatory organizations;
g) verifying information previously provided by a client with any other organization when necessary for the purposes provided in this Privacy Notice.
4. What We Will NOT Do With Your Information: We do not sell client information to anyone. Nor do we share client information with organizations outside of our relationship with you that would use it to contact you about their own products or services.
5. Electronic Transmission of Private Information: The Company will not send private client information via email or facsimile or other “electronic means” without client consent. Clients will be deemed to have consented to the use of electronic means to send to clients, or others specified by clients, information that contains private information by electronic (and encrypted, as required) means if a request is made for the information via electronic means. If a client specifically states that he/she does not want to have private information returned via electronic means, the client’s wishes will be honored, and alternative methods will be used such as Canada Post or courier.
6. Third Parties: The Company may collect client personal information for the purposes identified in this Privacy Notice from third parties such as financial advisors/dealers, other financial institutions, family members and from other parties who represent that they have the right to disclose the information. The Company may disclose client personal information for the purposes identified in this Privacy Notice to third parties such as client financial advisors, dealers, other financial institutions and service and product suppliers, Canadian governments and government agencies such as the Canada Revenue Agency, account statement preparation and mailing companies, Canada Post, courier, imaging and document storage companies. When the Company transfers personal information to their agents, such as mailing companies, it ensures by contractual means that the transferred personal information is used only for the purposes for which the agent is retained. If a client wishes to withdraw consent to the continuation of this information sharing or to discuss the implications of such withdrawal, a client may notify his/her advisor. In some circumstances, legal requirements may prevent a client from withholding consent. A client’s decision to withhold consent may also limit the products and services that the Company is able to provide because the disclosure to third parties is a necessary part of making the product or service available.
7. Using A Social Insurance Number: The Company is required by law to use a client’s social insurance number when submitting applications to third parties for products or services requested by the client and may provide it to third parties engaged to provide income tax reports.
8. We Strive to Protect Your Personal Information: All employees, associate advisors and suppliers who are granted access to client records understand the need to keep this information protected and confidential. They know they are to use the information only for the purposes intended and this expectation is clearly communicated. We have also established physical and systems safeguards, along with proper processes, to protect client information from unauthorized access or use.
9. Location of Client Accounts: Client records, in electronic, or paper format, are stored at the offices of the Company in Niverville, Manitoba, Medicine Hat, Alberta, and Kelowna, British Columbia. (Data stored in the cloud is encrypted in a secure Canadian cloud system). Paper records forming part of client records may also be kept in off site secure storage. Client records may be transferred to other locations for disaster recovery purposes. All client records are protected by physical locks or passwords.
10. Right to Access and Rectify Personal Information: Except in limited circumstances prescribed by the Protection of Personal Information and Electronic Documents Act (Canada) and similar provincial privacy protection legislation, a client is entitled to access, through a written request, the personal information contained in
his/her client record. A client may verify this personal information and request, in writing, that any inaccurate information be corrected. The Company can be contacted through the client’s advisor at (204)668-8722 or firstname.lastname@example.org.
11. Do Not Call Legislation: The Company follows all Do Not Call legislation unless we are notified. Acceptance of this letter allows us to contact all individuals that this notification is sent to ITI Financial Inc, one of its partners, advisors or administration personnel appreciates your business and promises to:
· Communicate with you in a timely and efficient manner
· Assess your application for investment, insurance and other services available to you by our firm
· Evaluate claims and underwriting risks when required
· Detect and prevent fraud
· Analyze business results
· Act as required or authorized by law
12. Your Privacy Choices: The Company complies with Canada's Anti-Spam Legislation and will obtain individual consent before sending electronic messages, which may include newsletters, promotions, announcements, invitations and other news or information.
· Clients may request copies of our privacy policies and procedures at any time.
· Clients may request access to their information. We must respond to this request as quickly as possible, but no later than 30 days after receipt of the request.
· Clients may withdraw their consent at any time (subject to legal or contractual obligations and on providing us reasonable notice) by emailing email@example.com or contacting our Privacy Officer, Adrienne Wiebe at firstname.lastname@example.org. Please be aware that withdrawing your consent may prevent us from providing you with requested products or services. We may occasionally use your personal information to advise you of products or services we believe may be of interest to you or fit your personal circumstances. Please inform us as soon as possible of any changes in the personal information such as marital status, employment status, health or other personal or financial circumstances that you have provided by contacting your advisor.
13. Exception to client access: Organizations must refuse an individual access to personal information:
· If it would reveal personal information about another individual unless there is consent or a life-threatening situation.
· If the organization has disclosed information to a government institution for law enforcement or national security reasons. Upon request, the government institution may instruct the organization to refuse access or not to reveal that the information has been released. The organization must refuse the request and notify the Privacy Commissioner. The organization cannot inform the individual of the disclosure to the government institution, or that the institution was notified of the request, or that the Privacy Commissioner was notified of the refusal.
Organizations may refuse access to personal information if the information falls under one of the following:
· Solicitor-client privilege
· Confidential commercial information
· Disclosure could harm an individual’s life or security
· It was collected without the individual’s knowledge or consent to ensure its availability and accuracy, and the collection was required to investigate a breach of an agreement or contravention of a federal or provincial law (the Privacy Commissioner must be notified)
· It was generated in the course of a formal dispute resolution process
14. Privacy Breach:
· If necessary, the affected client/s will be notified as well as the insurance carrier and/or investment firm.
· If necessary, we will notify our E&O insurance carrier.