Infinium Group Privacy Policy

Your Privacy is Important to Us
Infinium Group earns your trust by adhering to privacy principles in protecting your personal information. This notice is provided on behalf of Infinium Group, its subsidiaries and affiliates, Including Infinium Capital Corporation and Infinium Securities Inc. ("Infinium Group").

Definition of Personal Information The term "personal information" refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, personal information records, identification numbers, including your social insurance number (SIN) and your employment information. For business clients, information includes the above data plus names of officers, directors, owners, shareholders, jurisdiction of incorporation, financial information and ownership structure.

Why Do We Ask for Your Personal Information
Infinium Group may from time to time collect financial and other information about you. This information includes transaction-related details arising from your relationship with and through us. You authorize us to collect this information when you open an account with us, and during the course of our relationship. We may obtain this information from a variety of sources, including from you, from our records and from references you provide to us. Finally, we may also collect information from credit reporting agencies, other financial institutions or service providers.

Sharing Your Personal Information
We may use and your personal information with our employees, third party service providers and other financial institutions, but they will not share this information with others. The information may only be used for the following purposes:

  • to verify your identity and conduct background verification
  • to better understand your financial situation
  • to operate your account and provide you with products and services you may request
  • to set up, manage and offer products and services
  • if you provide us your social insurance number, we may share it with government authorities for tax purposes. We may share it with credit reporting agencies to ensure the accurate matching of credit history files
  • if you select to disclose or specifically direct us to disclose for you, your personal information to a third party (as in the case where you request a product, such as a mutual fund or a service from a third party, after receiving information or to securities issuers under National Instrument 54-101)
  • to meet requirement of legal and securities regulatory authorities and self-regulatory organizations including the Investment Industry Organization of Canada, the Investment Dealers Association of Canada, the Mutual Funds Dealers Association, and the Canadian Investor Protection Fund (Collectively, "SRO").
  • The only occasions we are permitted to disclose client information is when it is:

Authorized by the client;

  • Required or permitted by law;
  • Necessary to defend our interest; or
  • In the public interest.
  • Infinium Group has summarized the ten principles, which have been built upon the values set by the Canadian Standards Association's Model Code for the Protection of Personal Information and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Accountability.
Infinium Group is responsible for maintaining and protecting client information under its control.

Accuracy.
Infinium Group will keep personal information as accurate, complete and up-to-date as necessary for its purposes.

Consent.
The knowledge and consent of the customer are required for the collection, use or disclosure of Customer information except where required or permitted by law.

Identifying Purposes.
The purposes for which customer information is collected shall be identified before or at the time the information is collected.

Individual Access.
Upon request in writing, client shall be informed of the existence, use and disclosure of their information and shall be given access to it. Clients may verify the accuracy and completeness of their information, and may request that it be amended if appropriate.

Handling Customer Complaints and Suggestions.
Questions and concerns regarding personal information held by Infinium Group or about its compliance with the Infinium Group Privacy Code can be answered by our Compliance Department @ (416) 640-7133.

Limits to the Collection of Personal Information.
Infinium Group will limit the amount and type of personal information collected to which is necessary for its purpose. Personal information will be collected by fair and lawful means.

Limits to the Use, Disclosure of Personal Information.
Infinium Group will not use or disclose personal information for purposes other than those for which it was collected except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

Openness.
Infinium Group will make available review its policies and procedures regarding management of personal information. Infinium Group will ensure individuals are reasonably able to acquire information regarding Infinium Group policies and procedures and will make this information available in a form that is generally understandable.

Safeguarding Customer Information.
Customer information must be protected by security safeguards that are appropriate to the sensitivity level of the information. Every Infinium Group employee, as a condition of employment, takes responsibility for protecting customer privacy, confidentiality and security. This obligation remains in effect even after an employee leaves Infinium Group Suppliers of services to Infinium Group, such as data processing firms, are required to sign contracts obligating them to protect the privacy and confidentiality of personal information provided to them, to enable them to perform their function. Appropriate controls are in place over computer systems and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policies.

Infinium Group takes our responsibility for protecting the confidentiality of your personal information very seriously. If you have any other questions, please do not hesitate to contact our Compliance Department @ (416) 640-7133, send an email to cco@infiniumgroup.com, or write to:

Chief Compliance Officer
106 Front St. East
Suite 200
Toronto, ON M5A 1E1