This Privacy Notice applies to personal information ETG Commodities Inc. and its affiliates collect through the website- www.etgworld.com/northamerica and any mobile apps (hereinafter collectively the “Website”).

We are located at 6601 Goreway Drive, Unit B, Mississauga, Ontario, L4V 1V6.

We have appointed a Data Protection Officer who is accountable for our personal information handling practices. Our Data Protection Officer is Kent Gilroy. If you have a question or complaint about our personal information handling practices, please contact us at humanresources.canada@etgworld.com

In this Privacy Notice, the terms “ETG “ “we”, “our” and “us” mean ETG Commodities Inc. and includes our group of companies from time to time, including, without limitation, our subsidiaries, Dunnington Holdings Ltd., ETG Commodities Manitoba Inc., ETG Food Products Inc., ETG Commodities Ltd., and our parent and sister companies.

We would like to emphasize that we take the protection of your privacy and your personal information very seriously and that we process your personal information in accordance with applicable privacy laws.

1. What Personal Information We Collect:

1.1. Personal information is information that identifies you or could be combined by us or our service providers and affiliates with other information to identify you. This information includes your name, address, phone number, email address, username, password, feedback, IP address and location, digital device name, type and configuration, details relating to your download of publications (including details relating to the time of the download, any interruptions, and the success or failure of the downloads), the URL from which you accessed the Website, demographic information, and other similar personal information. If you are a business customer or prospective business customer, personal information does not include your title, business address and business telephone number when we use that information to contact you in your business capacity.

1.2. Source of Information: We collect your information from the following sources:

(a) information you give us when you fill out forms, such as during customer service inquiries and surveys;

(b) information from other sources, such as affiliates of our company with which you have purchased goods and services and companies that help us to update our records (see below for more information on our affiliates and service providers); and

(c) information that we collect automatically when you visit our Website, such as information about your browser settings and other information collected through cookies.

2. How We Use Your Information:

2.1. We use your information to enable us to provide access to the Website and to improve the layout and functionality of the Website. We use your information to provide products and services and to manage our business operations. We use your information for marketing and promotional purposes, including with our promotional partners. We combine all the information we collect other than information relating to your browsing history in order to understand your interests better and to analyze customer trends.

2.2. The email address you provide for order processing will only be used to send you information and updates, validate you as a customer when using our services, to respond to your enquiries and requests, to prevent and detect criminal activity, fraud and misuse of or damage to our services or networks, to prosecute those responsible and to contact you to invite you to form part of our consumer panel or various research groups. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. You can unsubscribe from our email list at any time by following the instructions included at the bottom of each email, or by contacting us via our Website.

2.3. We may use and disclose anonymous information, including aggregate anonymous information derived from your personal information, to inform publishers, partners, trusted affiliates, advertisers, and other interested parties as to the usage, habits or characteristics of our customer base, and to serve any other business purposes.

2.4. Other than as may be required in order to operate the Website or as otherwise described in this Privacy Notice, we may disclose your personal information to third parties for the following purposes:

i. to perform functions on our behalf (for example, to provide customer service or to provide domestic or international data hosting/storage services on cloud or otherwise) and, in such circumstances, these third parties will be provided access to only such personal information as is required to fulfill their functions (and only on the agreement that they not use your personal information for any other purposes); and

ii. to deliver publications to you, to verify your account information, to verify access to publications, to determine whether you meet the minimum system requirements for use of the service, to provide you tailored content and instructions, to provide you with targeted promotions, to provide customer support, and to seek your input regarding the Website.

2.5. We share information with our affiliates who may be outside of Canada and may be subject to laws that are different from those in Canada and such personal information may be used or stored by us or our service providers and our corporate affiliates outside of Canada. We require that our service providers and our corporate affiliates safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored. These affiliates may combine the information we provide with other information that they have collected from you.

2.6. Apart from the aforesaid, we may use third party service providers to help us operate our business, the Website, or administer activities on our behalf, such as sending out newsletters, direct advertising and marketing services or surveys.

2.7. We use your information to comply with and to carry out our contractual obligations to you. If such information is not provided, then we will not be able to manage our contractual relationship with you or to meet our obligations to you. In all other cases, provision of information is optional.

2.8. We will disclose personal information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your personal information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.

2.9. If ETG becomes subject to a merger, consolidation or acquisition, or becomes part of insolvency or bankruptcy proceedings we may be obliged to transfer your personal information to a third party and, in such case, we will take all commercially reasonable steps to require that the third party involved in such transactions or proceedings handles your personal information with no less care than taken by us.

2.10. We may also disclose your personal information if it is necessary for us to collect a debt from you, to enforce your contractual obligations to us or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so.

3. How Do We Protect Your Personal Information?

3.1 We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require our affiliates and any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them. To keep your personal information safe, we ensure that sensitive and private data exchanges between you and the Website happen over a Secure Sockets Layer (SSL)-secured communication channel and are encrypted and protected with digital signatures. SSL-secured communication channels are specially designed to protect personal and sensitive information, which is sent over the internet.

3.2 We take all steps reasonably necessary to protect against the unauthorized access, use, alteration, disclosure or destruction of personal information.

3.3 Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our Website if you consider that information to be sensitive.

4. Links to Third-Party Websites and Social Network Plug-Ins.

4.1 In the future, you may be able to access third-party websites through links available on our Website. You may also be able to connect to social networks such as Twitter, Linked In, Instagram and Youtube. These links will be provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites will be at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Notice. Do not transmit personal information using those websites without reading the privacy policies governing those websites.

4.2 You may create links between our Website and social networking sites. If you do so, we may be able to publish updates about our products and services to your social network account through the links that you establish. You may terminate those links at any time by modifying your social network account.

4.3 If you are logged into a social networking site when visiting our page, your visit to our Website will be personalized based on your social networking profile.

4.4 You may change the way social networking sites and our sites interact by modifying your privacy settings in your social networking account. You can also log-out of your social networking account before visiting our Website. For more information, please refer to your social networking site’s privacy policy, which governs your use of these social plug-in features.

5. Data Retention.

5.1 We retain your information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.

6. Regarding Minors.

Our Website and the services offered on our Website are not directed to persons under the age of 18 years. We will not knowingly collect personal information about a person under the age of 18. We do not allow minors (persons who are under the age of majority in their place of residence) to enter contests or promotions.

7. How to Contact Us.

7.1 If you have a privacy question or concern, please contact us at: humanresources.canada@etgworld.com

7.2 If you have questions or concerns about our privacy practices or about your personal information collected by us, please contact our Data Protection Officer at 416 900 4148 ext. 725.

7.3 You may ask ETG for a copy of your information, to correct it, erase or restrict its processing, or to ask us to assist you to transfer some of this information to other organizations. You may also have rights to object to some processing activities, such as the profiling we may perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. You may review or update the personal information that we hold in respect of your account by contacting us at: humanresources.canada@etgworld.com

8. Notice to Persons Outside of Canada.

This Privacy Notice is governed by the laws of Canada and applicable provincial laws. By submitting personal information to us, you understand that your personal information will be subject to the laws of Canada and applicable provincial laws.