Privacy Policy Independent Direct

Privacy Policy

Protecting the Personal Information entrusted in our care is important to us. We respect the privacy of our customers and are committed to safeguarding all Personal Information or data entrusted to us. The Privacy Policy applies to Independent Trading Group.

We do not engage in any practice that contradicts the Privacy Policy. This includes:

selling Personal Information to third parties;
publishing Personal Information with the intended purpose of charging individuals for its removal
collecting, using, or sharing Personal Information that is otherwise unlawful; or
profiling or categorizing clients in a way that leads to unfair, unethical, or discriminatory treatment contrary to human rights law

We are committed to safeguarding your Personal Information. Upon request and in accordance with applicable privacy requirements, we will disclose how we use your Personal Information and with whom we may share it. We will also:

limit the Personal Information we collect to what is required and will only use it for those purposes;
only use your Personal Information for the purposes it was obtained (and we will obtain your consent before using your Personal Information for another purpose);
ensure that the service providers and contractors who have access to or are provided with your Personal Information are bound to protect your information and will not use it for any unauthorized purposes; and
train our employees to ensure that your personal information is handled appropriately and to reiterate the importance of treating it with the utmost care.

I. What is Personal Information?

“Personal Information” is any information about an identifiable individual. It may include, without limitation, an individual’s name, age, date of birth, home address, social insurance number, marital status, income, account number, client identification number, personal email address and messages, and Internet Protocol (IP) address.

Personal Information does not include the business contact information of an individual which is collected, used, or disclosed solely for the purposes of communicating or facilitates communication with the individual in relation to their employment, business, or profession.

Personal Information also does not include any information that is aggregated or anonymized.

II. What Personal Information Do We Collect?

We collect and use several types of information from and about you to better provide products and services to you. Depending on the product or service you have with us, this may include:

Personal Information (such as your name, address, contact information, date of birth, occupation and any other type of identification including your driver’s license);
Financial and bank information including your credit score and information about your assets, liabilities, income and expenses;

Tax information (including Social Insurance Number (SIN);

Employment information;
Information about your interests and purchasing preferences; and
Information about your transactions with us and our interactions with you (including call recordings and chat transcripts).

Collection of Social Insurance Number (SIN) for Identity Verification (Optional)

Depending on the products or services you have with us, we may also request (with your consent) your SIN to verify your identity through an established credit reporting agency. This will apply for all accounts, with the exception of registered accounts (i.e., RSP, RESP), which do not require the use of a SIN for identity verification. However, if we do request that you provide us with your SIN for a reason other than for income tax reporting purposes, providing us with your SIN is optional and you can refuse our request for this information.

III. How is the Personal Information Collected?

The Personal Information we have about you may be collected directly from you (or anyone authorized by you to act on your behalf under a power of attorney or other legal authority) using a variety of means (including technological mediums). In addition, we may employ technologies that identify, locate, or profile you. This information may be collected from sources within or outside of our Company including from (depending on the product or service you have with us):

our interactions with you (including email, instant messaging/chat, telephone and video calls);
government bodies, agencies, registries; regulatory bodies, and law enforcement authorities;
public records;
law enforcement authorities;
public records;
third party service providers (including financial data aggregators) and professional advisors (such as accountants and lawyers);
other financial or lending institutions;
credit reporting agencies including Equifax Canada Inc. and Trans Union of Canada, Inc.;
our affiliates, partners, and related entities; and
organizations with whom you have arrangements or any other sources we deem appropriate (where the information obtained will help us serve you).

Call Recordings

We may record telephone or video calls made or received by our agents and employees for quality assurance and security purposes. If you do not want your call to be recorded, please notify the agent on the call. We keep recordings of calls only for as long as permitted by law.

Providing Consent of Others Including Minors

You may disclose Personal Information about others with consent from such individuals. Where you are disclosing Personal Information about minors, you are doing so as the minor’s parental authority or tutor.

IV. Why Do We Collect Your Personal Information?

The Personal Information collected is used to ensure we can provide products and services to you and fulfill our obligations to you.

We may use your Personal Information for purposes including to:

verify your identity (as applicable, there may be instances where your identity is verified with third-parties who rely on telecommunication service providers);
determine your eligibility for products, services or coverage for which you are applying for;
administer your account and product and services you may have with us (including the administration of claims);
Complete an application or communicate with you (including responding to any inquiries you may make);
evaluate and process your application, accounts, transactions, and reports;
help manage and assess our risks including risk of default, operations and relationship with you;
comply with applicable laws, internal policies and requirements of regulators, including self-regulatory organizations; and

V. How Long Will We Keep Your Personal Information?

Personal information will not be used, disclosed, or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law. Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

VI. To Whom Do We Disclose Your Personal Information?

In order to provide you with the best products and services, we may need to share your Personal Information with other parties who are under an obligation to protect the confidentiality of that information. The shared information will be limited to such information which is necessary to facilitate the arrangement.

Your Personal Information may be disclosed:

to carry out a mandate or perform a contract of enterprise or for services;
to respond to a court order, search warrant, or any other valid demand or request;
to satisfy any applicable legal or regulatory requirement (including to a self-regulatory organization of which we are a member);
to any advisors we may engage which may include financial advisors, consultants, accountants, lawyers, and auditors;
to suppliers, service providers, agents or other organizations that perform services for you, for us or on our behalf;
to any authorized individual with legal authority including Power of Attorney;
where otherwise permitted by law.

Protecting your Personal Information

Please note that sharing your Personal Information with us does have certain risks including risk of unauthorized disclosure of Personal Information, identity theft, and fraud. We take the protection of your Personal Information very seriously and deploy various technical, administrative, and physical safeguards to protect your information.

VII. Privacy Questions, Concerns, or Complaints

Updates to Our Privacy Policy

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email using the email address specified in your account or place information banners on our website. We will include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy specifically to check for any changes.

Contact Us

If you have any questions or concerns about this policy or privacy and confidentiality matters, please contact our Chief Privacy Officer at:

Independent Trading Group

33 Yonge Street, Suite 420
Toronto, ON M5E 1G4 Canada
Phone: 416.583.2194
Email: info@itg84.com

Contact the Office of the Privacy Commissioner of Canada

If, after contacting Independent Trading Group, you feel your Personal Information concerns have not been adequately addressed, you may contact the Office of the Privacy Commissioner of Canada at:

30 Victoria Street
Gatineau, Quebec
K1A 1H3

Phone: 416-543-8484
Online: https://www.priv.gc.ca/en/report-a-concern/

Social Media Policy

The Social Media Policy applies to Independent Trading Group.

This Social Media policy makes reference to Personal Information. “Personal Information” is any information about an identifiable individual. It may include, without limitation, an individual’s name, age, date of birth, home address, social insurance number, marital status, income, account number, client identification number, personal email address and messages, and Internet Protocol (IP) address. Personal Information doesn’t include business contact information of an individual which is collected, used, or disclosed solely for the purposes of communicating or facilitates communication with the individual in relation to their employment, business, or profession. Personal Information also doesn’t include any information that is aggregated or anonymized.

We are committed to maintaining and respecting your privacy. While we are active on social media, the social media platforms and sites used by us are in no way affiliated with our organization. You should always use care and discretion when using social media platforms. Any Personal Information you privately share with us through these platforms may be shared with our employees, representatives, affiliates, or third-party service providers. These third-party service providers may be responsible for handling our social media accounts, including responding to any of the questions or issues you raise. As these individuals and service providers may in some cases be located outside of Canada, the Personal Information you share could be subject to access under the laws of such foreign jurisdictions. You should not share any sensitive Personal Information with us via social media.

The content you comment on or post on our public social media pages is public; meaning anyone who visits our social media pages may see it. When you share information in public comments or posts, you acknowledge and agree that it is not confidential, and that if you are sharing information of another individual, you have their permission. To help maintain your privacy and the privacy of others, we discourage you from sharing any Personal Information on our social media pages, including sending us Personal Information through private messages on social media.

We reserve the right to remove any posts you make on our social media pages violating our privacy policy. In addition, we reserve the right to remove:

sensitive Personal Information (no Personal Information should be posted or sent privately to us on our social media pages);
personal attacks, or defamatory, abusive, or hateful comments; or
spam posts, along with links to any content unrelated to our social media accounts or links to any content that may contain viruses.

Company Content on Non-Company Accounts

In consultation with us, content related to or made for us may be posted on the social media accounts of third parties (“Third Party Content”). Where such Third Party Content is posted onto the account of a third party, or a third party posts Third Party Content which includes the brand, name, or trademark of the Independent Trading Group, we reserve the right to require edits/amendments to be made to the Third Party Content or for the Third Party Content to be removed in its entirety. It is possible that Third Party Content on third party social media accounts may be created about or for us without our knowledge or prior agreement. If any such Third Party Content violates our policies or procedures and the third party who has posted such Third Party Content has not complied with our required edits/amendments or requests for removal, we may report such content to the social media provider to be removed on its behalf.

We may change, remove, or add to our social media policy at any time without notice to you.

If you have concerns about your Personal Information being shared on any of our social media platforms, please contact info@itg84.com.

Online Access Agreement

Terms of Use

By accessing this website and any of its associated websites or mobile applications (the “Site”), you acknowledge these terms and conditions of use and agree to be bound by them. If you do not agree to these terms, please discontinue accessing the Site immediately.
We reserve the right, in our sole discretion, to modify, alter or otherwise update these terms and conditions at any time and you agree to be bound by such modifications, alterations or updates.
The content of the Site is published by Independent Trading Group (“Independent Direct”) and its affiliates.
This Site is only intended to provide you with general information and is neither an offer to sell nor a solicitation of an offer to purchase any security and may not be relied upon for investment purposes.
Any commentaries and information contained in the Site should not be considered personal investment advice.
Information on the Site is not intended to provide legal, accounting, financial or tax advice, and should not be relied upon in that regard. Please consult with your professional advisor with respect to your particular circumstances.
The Site is provided on an “as is” and “as available” basis, without any representations, warranties or conditions of any kind, whether expressed or implied, and including without limitation implied representations, warranties or conditions of title, non-infringement, merchantability, fitness for a particular purpose, performance, durability, availability, timeliness, accuracy, or completeness, all of which are hereby disclaimed by Independent Trading Group to the fullest extent permitted by law.
Every effort has been made to ensure that the material contained on the site is accurate at the time of publication. However, Independent Trading Group will not under any circumstances be liable to you or any other person in any way for any loss or damages (direct, indirect, special, economic, incidental, consequential, punitive or exemplary, including without limitation loss of revenue, data, anticipated profits or lost business) in respect of use of, or inability to use, or any reliance on, the Site, any of its content or links (including without limitation any inaccuracies or viruses), or any web browser or other equipment.
By accessing the Site, you agree to indemnify and hold harmless Independent Trading Group and its agents, suppliers and their respective directors, officers and employees from and against any and all actions, proceedings, costs, claims, liabilities, damages and expenses (including reasonable legal fees) arising from or in connection with a breach of these terms and conditions or the use of this Site.
The contents of the Site are protected by applicable copyright and trademark laws. Unauthorized use or exploitation of such content is strictly prohibited including without limitation, unauthorized downloading, retransmission, storage in any medium, copying, redistribution, reproduction, or republication of the Site, or any part thereof, for any purpose.
Other sites accessed by hypertext appearing in the Site may have been independently developed by parties other than Independent Trading Group. Independent Trading Group does not guarantee the accuracy of information contained in such other sites.
Links to other sites should not be taken as Independent Trading Group’s endorsement or approval of such other sites, the third parties named therein, or their products and services, nor is any liability assumed for incompatibility, non-suitability, viral infection or other destructive/disruptive components on or from such other sites.
The framing, mirroring, scraping or data-mining of the Site or any of its content in any form and by any method is strictly prohibited.
Independent Trading Group cannot guarantee complete confidentiality or security for information that is transmitted electronically. By accessing the Site, you acknowledge that Independent Trading Group is not responsible for any damages or losses you may suffer as a result of your electronic transmission of confidential or sensitive information to us.
No consent or waiver by either party to, or of any breach or default by, the other party in its performance of its obligations under this agreement will be deemed or construed to be a consent to, or a waiver of, a continuing breach or default or any other breach or default of those or any other obligations of that party. No consent or waiver will be effective unless in writing.
If any provision of these terms and conditions is found to be unlawful, void, or for any reason unenforceable, then that provision shall be deemed to be severed from the rest of these terms and conditions and shall not affect the validity and enforceability of any remaining provisions.
These terms and conditions are governed by the laws of Ontario and the laws of Canada applicable therein, excluding any conflict of laws which would lead to the application of any other laws. By accessing the Site, you hereby irrevocably submit and attorn to the provincial and federal courts located in the City of Toronto, Ontario for any disputes or matters arising from, connected with, or relating to the Site, this agreement or any related matters.