Terms & Privacy

BroadGrain Commodities Inc. (“BroadGrain”) is committed to respecting the privacy of individuals and providing security for personal information. BroadGrain recognizes our clients’ (including potential clients) need for the appropriate management and protection of any personal information that you agree to provide to us. This privacy policy complies with the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and is consistent with common law rules governing duties of confidentiality.

Accountability: This privacy policy includes guidelines regarding the collection, use, storage, retention and disclosure of your Personal Information. BroadGrain is responsible for all personal information under its control and its Privacy Officer is accountable for Seaforth Financials’ compliance with the principals described in this Privacy Policy.

Collection and usage: BroadGrain collects personal information about individuals in order to: (i) better manage it’s business; (ii) comply with applicable laws and regulations; (iii) execute client requests; (iv) evaluate risks; and (v) protect against fraud. The purpose for which personal information is collected will be disclosed and documented at or before the time that the personal information is collected. The organization will make all reasonable efforts to fully inform such individuals about the planned use or disclosure. BroadGrain will collect personal information from: (i) telephonic recordings; (ii) corporate applications; (iii) consumer credit agencies; and (iv) other third parties. Telephonic recordings and monitoring are required for quality control and training purposes as well as to evidence business transactions. Personal information collection will be limited to that which is necessary for valid business purposes or to comply with legislation by fair and lawful means.

Individual consent: BroadGrain requires an individual’s knowledge and consent (express or implied) for the collection, use or disclosure of personal information, except as otherwise required or permitted by law. BroadGrain 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.

Accuracy: The organization will make every reasonable effort to ensure that the personal information it collects and uses is accurate, up-to-date and complete. Individuals providing personal information will have the opportunity to review and correct their personal information upon written request. The organization will modify the information as required.

Storage: The organization will store personal information using hard copy and/or electronic means in such a way as to prevent loss, theft, unauthorized collection, access, modification, use, disclosure or disposal of the personal information. The physical, organizational and technological safeguards in place to protect personal information will be appropriate to the sensitivity of the information. Personal information is protected at BroadGrain by:
(i)entering written confidentiality/non-disclosure agreements with third party service providers for certain disclosures; (ii) restricting access only to those employees who need to know that information in order to provide products or services; and (iii) maintaining physical, electronic and procedural safeguards that comply with the relevant laws and regulation.

Retention: The organization will establish a retention period for all personal information collected. This period may be related to legislation other than PIPEDA.

Disclosure: The organization will not disclose personal information unnecessarily to employees or any third party, unless the effected individual consents.

Access: BroadGrain will grant access to personal information upon written request. Access will be provided according to established procedures. BroadGrain will inform an individual of the existence, use, and disclosure of his or her personal information and will provide access to that information, except where the law requires or permits Seaforth Financial to deny access.

Use of Agents and Third Parties: In addition to the care that BroadGrain takes directly, we are also working with all of our partner organizations that may at some point handle personal information gathered by us in the course of their relationship with and service to us. We do not disclose non-public information to third parties with the exception of: (i) information system and compliance consultants engaged to ensure the confidentiality and security of our records; (ii) where compelled or permitted by law such as government and law enforcement agencies; (iii) to providers of financial services, including banks, for risk control or requested services, and/or to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; and (iv) to any person where we have obtained your written consent.

Each third party partner has agreed to meet our standards of privacy, confidentiality and security. All Employees and third party staff who in any way handle or manage Personal Information have acknowledged and agreed to adhere to our Privacy Code and the procedures that support that code.

For further information contact:
Chief Privacy Officer
(416) 504-0070