Privacy Policy

Strategic Capital & Intelligence Group Ltd. (SCIG)

Original Effective Date: April 1, 2010
Last Updated: July 6, 2026

1. What Information We Collect

We collect personal information you voluntarily provide when interacting with SCIG, including:

•Name
•Organization name
•Email address
•Telephone number
•Message content submitted via our contact form or email correspondence
•IP addresses (automatically logged by our web infrastructure)

2. Why We Collect It

Personal information is collected and used solely for the following purposes:

•Responding to your inquiries and providing advisory services
•Maintaining client relationships and communications regarding engagements
•Fulfilling legal, regulatory, and contractual obligations
•Protecting the security and integrity of our operations

We do not collect, use, or disclose personal information for purposes beyond those identified above without obtaining your consent.

3. How Long We Retain Your Information

Personal information is retained for a period of seven (7) years from the date of last interaction or conclusion of an engagement, whichever is later. This retention period is based on:

•Ontario's general limitation period for contract and tort claims under the Limitations Act, 2002
•Canada Revenue Agency record-keeping requirements
•SCIG's operational obligation to maintain engagement records for accountability purposes

Upon expiry of the retention period, personal information is securely destroyed or permanently deleted.

4. Data Transmission and Storage — Proton Infrastructure

All data transmitted by or stored on behalf of SCIG is processed through Proton AG, a Swiss corporation, global server infrastructure and data storage centres, and is protected by end-to-end encryption.

This means:
•Data is encrypted on SCIG devices before transmission — no intermediary, including Proton, can access the content
•Stored data remains encrypted at rest on Proton's servers
•SCIG retains sole control over decryption keys
•Zero-access encryption ensures that even Proton's infrastructure administrators cannot read SCIG data

SCIG remains accountable for all personal information under our control, regardless of the physical location of Proton's servers, consistent with our obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA).

5. Who Has Access

Access to personal information is restricted to:

•Authorized SCIG staff who require access to fulfill the purposes identified in Section 2
•Proton, as our infrastructure provider, solely for the purpose of data transmission and encrypted storage — Proton cannot access the content of any data due to end-to-end encryption
•Cloudflare, Inc., used solely for form spam prevention on our website

We do not sell, rent, or trade personal information to any third party.

6. Your Rights

Under PIPEDA, you have the right to:

•Access — Request a copy of the personal information we hold about you
•Correction — Request that inaccurate or incomplete information be corrected
•Withdrawal of Consent — Withdraw consent for future use of your information, subject to legal and contractual obligations
•Complaint — Lodge a complaint regarding our handling of your personal information

Requests may be submitted using the contact information in Section 7.

7. How to Contact Us

For privacy-related inquiries, access requests, corrections, or complaints:

SCIG Privacy Officer

Strategic Capital & Intelligence Group Ltd.

18 King Street East, 14th Floor 
Toronto, Ontario, Canada M5C 1C4

Email: privacy@scig.global

If your concern is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada:

•Website: www.priv.gc.ca
•Toll-free: 1-800-282-1376

8. Security Safeguards

In addition to Proton's end-to-end encryption, SCIG implements the following safeguards:

•Access controls limiting personal information to authorized personnel only
•Encrypted communication channels for all client correspondence
•Internal policies governing data handling, access, and destruction
•Regular review of security practices

9. Changes to This Policy

SCIG may update this policy from time to time. The most current version will always be posted on our website. Material changes will be communicated to active clients via email.

10. Accountability

SCIG is responsible for personal information under our control and has designated a Privacy Officer accountable for compliance with this policy and PIPEDA.