Privacy Policy

Last Updated: August 2026

InterGroup Consultants Ltd. (also referred to as “InterGroup”, “us”, or “we”) respect your privacy and are committed to protecting it. We have created this privacy policy (the “Privacy Policy”) to explain, among other things:

What kind of personal information we collect and how (Section 2);
Why we collect your personal information and how we use it (Section 3);
Who your personal information may be shared with (Section 4);
Any potential risks associated with the collection, use and disclosure of your personal information (Section 6);
Your choices (Section 7); and
How you can contact us about our privacy practices (Section 16).

We want this Privacy Policy to be accessible to everyone, including those with disabilities. If you need this Privacy Policy in another format, please contact our Privacy Officer using the information in Section 16.

This Privacy Policy applies to information we collect, use, or disclose about you:

on the website https://intergroup.ca/ (the “Site”) and any other websites or pages that we own or operate (collectively and together with the Site, the “Sites”),
in email, text, and other electronic communications,
when you interact with us in person or over the phone, and
when we are engaged in and providing consulting services, which can include (but is not limited to) public engagement, project management, impact assessments, research, and expert advice and support (“Consulting Services”)

(collectively and together with the Sites and Consulting Services, the “Services”).

By accessing, using or otherwise participating in the Services, you consent to the collection, use and disclosure of personal information by InterGroup in accordance with this Privacy Policy. This Privacy Policy may change from time to time. See Section 18 for more information.

You don’t have to share your personal information with us, and if you have shared your personal information with us you can withdraw your consent at any time (subject to legal or contractual restrictions and reasonable notice). However, if you don’t consent or if you withdraw consent, we may not be able to provide you with parts or all of the Services.

You should read this whole Privacy Policy so that you understand our practices, but we have organized it according to questions you might have for us, so you can also use the links below to jump to specific answers.

1. What are the key defined terms used throughout this Privacy Policy?

2. What personal information do we collect?

3. Why do we collect and use your personal information?

4. To whom do we disclose your personal information?

5. How do we protect your personal information?

6. Are there any potential risks of harm or other consequences to you in providing your personal information to us?

7. What are the choices you have and how can you exercise them? For example, how can you withdraw your consent if you change your mind? Are there any circumstances where we don’t get your consent? What about cookies and targeted advertising? How can you unsubscribe from emails and newsletters?

8. What if there is a change in the initial purpose for the collection of your personal information?

9. Do we knowingly collect personal information about children?

10. Do we transfer your personal information to third parties for storage or processing?

11. How long do we keep your personal information?

12. Do we collect, use, and disclose non-personal information about you?

13. How do we make sure your personal information is accurate?

14. How can you access your personal information?

15. Do we have links to other websites on the Sites? If so, which privacy policy governs?

16. Who do you contact if you have a question or complaint, or want to access or correct your personal information?

17. How do we handle complaints?

18. If changes are made to this Privacy Policy, will you be notified? If so, how will you be notified?

1. Definitions

For the purposes of this Privacy Policy, the following words have the following meanings:

“collection” means the act of gathering, recording or obtaining personal information from any source (including third parties) by any means.

“consent” means informed and voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by you or sometimes, by someone on your behalf (like a parent or guardian). Express consent is given when you take a positive action to indicate consent (whether orally, electronically or in writing). Implied consent is when consent is assumed based on your actions or inactions that suggest consent is reasonable.

“disclosure” means making personal information available to a third party.

“employee” means an employee of InterGroup, and for the purpose of this Privacy Policy only, includes agents, independent and other contractors performing services for InterGroup.

“non-personal information” means information that does not identify you and which we cannot link to other information to identify you (e.g., anonymized, statistical, or aggregated data).

“Organization” means a company, entity, or organization, including any business, but does not include an individual.

“personal information” means information about an identifiable individual, but not anonymized or aggregated data that cannot be linked to a specific individual.

“third party” means an individual or Organization other than the user, the user’s agent, or InterGroup.

“use” means the treatment, handling and management of personal information by and within InterGroup.

“user” means any individual or Organization that visits the Sites and/or accesses/uses the Services.

2. Information We Collect

When you use the Services, we may collect different types of information, including personal information, non-personal information, and technical information. We collect this information in different ways, including through:

Direct interactions with you, like when you fill out forms or participate in interviews, and
Automated technologies, like through cookies as you browse our Sites.

Personal Information

Our clients are primarily entities like businesses and governments. As such, we don’t collect much personal information from or about our clients. However, the work we do on behalf of our clients can involve public engagement. For example, some projects may require us to conduct interviews with certain stakeholders or surveys of the general public in order to provide the report our client has asked for.

We may collect and use any or all of the following personal information for the purposes described in Section 3 of this Privacy Policy:

a) Engagement Information: Information that you provide when you engage with InterGroup as a client (e.g., name, title, company name, email address, postal address, and telephone number;

b) Payment Information: If we are paying an honorarium to a participant, we may collect your email address or mailing address to pay you via electronic fund transfer or by mailing a cheque to you. Generally speaking, our clients are businesses, so any payment information we receive when our client’s pay us is not personal information; however, occasionally an individual might retain us, in which case we receive any personal information that may be included in your method of payment, such as personal address or account numbers if they are included on your cheques;

c) Correspondence: any questions, concerns, or comments you share with our employees;

d) Client Generated Content: Comments, videos, photographs, and any other content submitted to us or generated by us while providing the Services. For example, we may take photos while working on a particular project that are then posted on the Sites, but we will only do this with your consent;

e) Stakeholder or Rights Holder Information: Personal information that third parties such as stakeholders, rights holders, key people within an organization, or members of the public provide when we conduct interviews and surveys on behalf of our clients. This may include, but is not limited to, an individual’s name, title, business name, phone number, email address, and opinions about specific issues. We also collect non-personal information about communities, both Indigenous and non-Indigenous; and/or

f) Service Requests: Details of any requests you submit to us, whether through via email, over the phone, in person, or otherwise.

When we interview stakeholders, rights holders and other third parties on behalf of our clients, we will provide specific information about who we are working with, the purpose of the interview, what will be done with the information provided, and how it will be protected. Depending on who we are working with and any applicable governing body, we may have additional obligations, but at the core of all of our practices is the process of informed consent based on guidance from the Tri Council Policy Statement on Ethical Conduct for Research Involving Humans. We provide participants with the necessary information at the time of the interview so that they have the opportunity to ask additional questions and to ensure that w have express, informed consent.

Cookies

The Sites use only strictly necessary cookies that are essential for a website to function properly and to allow you to navigate and use its features. Because these cookies are required for the Sites to function, you cannot opt out of these cookies.

3. Purpose of Collection and Use of Personal Information

InterGroup collects and may use your personal information for the following purposes:

a) to provide the Services to you, and/or the other services or information that you request;

b) to fulfill the purposes for which you provided the information, or any other purpose we disclose to you (with your consent). This includes personal information that we collect from third party stakeholders or rights holders that have participated in interviews or surveys we conduct on behalf of our clients;

c) to verify your identity;

d) to display reviews, photos or videos on the Sites with your consent;

e) to respond to questions, comments, requests, job applications, or complaints that you submit to InterGroup;

f) to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection, if applicable;

g) to process payments made by you to InterGroup or to pay honorariums to participants, where applicable;

h) to detect, investigate or prevent fraudulent activity or other activity that may be illegal, violate our policies, cause us or others harm or compromise our security;

i) to protect our rights and property, as well as those of others;

j) to send emails, newsletters, other communications that we have to send you, or that you consented to receive;

k) to provide Services-related announcements or notifications to you;

l) for quality assurance and to train our staff;

m) to analyze usage and improve the Services, our other products and services, marketing and client experiences;

n) to anonymize your personal information or aggregate it with other data in a way that no longer personally identifies you;

o) to maintain appropriate records for internal administrative purposes;

p) to meet legal and regulatory requirements; and/or

q) where otherwise required or permitted by applicable laws.

Access to and use of your personal information within InterGroup is restricted to employees, contractors and service providers who need it to complete the purpose for which the personal information was collected, including to enable them to perform a business, professional or technical support function for InterGroup. When we share information with our contractors and service providers, they are contractually obligated to protect your personal information and use it only for the purposes for which we have transferred it to them.

4. Disclosure of Personal Information

InterGroup may disclose your personal information in the following circumstances:

a) With Consent: We disclose your personal information as necessary to fulfill the purpose for which you provided the information or any purpose for which you have given consent.

b) Agents. We may disclose your personal information to a person who, in the reasonable judgment of InterGroup, is seeking the information as your agent.

c) Enforcement and Protection. We may disclose your personal information to a third party or parties to enforce an agreement we may have with you (including to collect payments), or if we believe it is necessary or appropriate to protect the rights, property, or safety of InterGroup, our employees, our clients, or others. For example, if we believe you are engaged in fraudulent activity or other activity that may be illegal, violate our policies, cause us or others harm or compromise our security.

d) Corporate Transactions. We may disclose your personal information during corporate transactions, like re-organizations, mergers, an amalgamation with another entity, a sale of all or a substantial portion of our assets or shares, or financing activities. This includes sharing data during due diligence for these transactions. Any such disclosure will comply with applicable privacy law, including requirements to enter into agreements to protect your personal information.

e) Legal Compliance. We may disclose your personal information where the disclosure is permitted or required by law. For example, to comply with a subpoena, warrant or other order made by a court or other body with the jurisdiction to compel the disclosure.

5. Safeguarding Your Personal Information

InterGroup is committed to safeguarding your personal information through a combination of administrative, technical, and physical safeguards to protect against risks such as loss, unauthorized access, misuse, alternation, destruction, or any other unlawful processing. The methods of protection and safeguards used by InterGroup include, but are not limited to:

Administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for InterGroup employees;
Technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks; and
Physical safeguards such as locked filing cabinets, and need-to-know access for InterGroup employees, partners, subsidiaries, affiliates and service providers.

6. Potential Risk of Harm and Other Consequences

While we have implemented safeguards to reduce the risk of a privacy breach, we cannot guarantee absolute security. The nature of digital systems and internet communications means that it is possible our safeguards may be breached by third parties, who may misuse your personal information.

The risks that come from a breach can include financial loss, identity theft, reputational harm, damage to relationships, and loss of employment or business opportunities, among other things. The more sensitive the personal information, the more significant the possible harm.

You are providing your personal information at your own risk.

7. Choices About How We Use and Disclose Your Information

a) Consent

The consent required can be express or implied, depending on the circumstances. We will only process your personal information without your knowledge or consent where this is permitted or required by law.

You can withdraw your consent to the collection, use, or disclosure of your personal information by InterGroup at any time, subject to legal or contractual restrictions and reasonable notice. More specific examples of how you can control the use of your personal information are described below.

If you withdraw your consent, we may not be able to provide you with some or all of the Services. Please contact our Privacy Officer using the information in Section 16 to withdraw your consent or for more information about how doing so may affect your access to the Services.

b) Newsletters and Promotional Material

We may send you marketing or promotional messages if:

You’ve given us permission to do so.
You’ve entered into a contract with us or have some other kind of business relationship with us.
You’ve asked for information from us.
The law allows us to send these messages.

If you don’t want to receive these messages anymore, you can unsubscribe here. However, even after unsubscribing, we might still send you important messages like service updates, bills, or other legally required information.

8. Change of Purpose

InterGroup will only use your personal information for the purposes for which it was originally collected, unless required or permitted by law, or where the new purpose is compatible with the original purpose (based on factors like the relationship between the purposes and your reasonable expectations).

If the new purpose unrelated, we’ll notify you and get consent where required (see Section 18 for more information).

9. Children

The Services are intended for general audiences. Some projects require engagement with individuals under the age of 18, in which case we require consent from their parent or guardian before we collect any information from or about them.

We do not knowingly collect personal information from minors, or from any other individual incapable of providing consent on their own behalf, without the consent of that individual’s parent, legal guardian, attorney under a valid power of attorney, or other person capable of consenting on behalf of the individual. If we learn that we have collected personal information from such an individual without appropriate consent, we will delete that personal information. If you think such an individual has provided us with personal information, please contact our Privacy Officer using the information in Section 16.

10. Cross Border Transfer of Personal Information

Subject to any agreement to the contrary, your personal information may be stored and processed in any province or country where our third-party service providers operate (e.g. Canada, United States). Your personal information is subject to the law of that jurisdiction, which may allow access by their governments, courts, law enforcement or regulatory agencies. For example, personal information stored in the United States is subject to the USA PATRIOT ACT.

InterGroup has measures in place to protect your personal information during cross-border transfers in accordance with data protection laws, like contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used.

11. Retention of Personal Information

InterGroup will keep personal information only as long as reasonably necessary to fulfil the purposes outlined in this Privacy Policy and to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we will consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for processing your information and whether they can be achieved through other means, and any applicable legal requirements.

12. Non-Personal Information

InterGroup may collect or create non-personal information, including by anonymizing your personal information or aggregating data collected from you with other data in a way that no longer personally identifies you. We don’t try to link this non-personal information with the identity of individuals. Non-personal information, including anonymized and/or aggregated data, is not personal information, and is not subject to this Privacy Policy. We may permanently archive non-personal information for future use in any manner whatsoever.

13. Accuracy of Personal Information

InterGroup is committed to keeping your personal information as complete, up-to-date, and accurate as necessary for its intended purposes. Upon request and to the extent required under applicable law, we will promptly correct or complete any inaccurate or incomplete personal information. Where appropriate, we’ll send the updated information to third parties that have access to the personal information in question.

You can request an update or correction of your personal information by contacting our Privacy Officer using the information in Section 16.

14. Access to Personal Information

You have the right to access your personal information and understand how it has been used and disclosed by InterGroup, subject to certain exceptions.

Upon request, and to the extent required by law, we will provide you with:

a) access to your personal information (subject to the below) to review its accuracy within a reasonable time and at minimal or no cost; and

b) information about how your personal information has been used and disclosed, including the source of that information if possible. If providing a specific list of disclosures is not reasonably possible, we will provide a list of organizations to which your personal information may have been disclosed.

Sometimes, we may be prevented from providing you with access to some or all of your personal information. Applicable law sets out these exceptions to access. If that’s the case, we’ll explain our reasoning.

To request access to your personal information, contact our Privacy Officer using the information in Section 16. If you need help preparing a request for access to information, let us know and we will help you.

15. Links to Other Websites

The Sites may contain links to other sites, like Facebook or YouTube. This Privacy Policy only applies to how we handle your personal information. We are not responsible for how these third parties handle your personal information. Before you share anything with them, we strongly recommend reading their privacy policies to understand how they handle your personal information.

16. Contact Us

To ask a question, file a complaint, request access to, correct or update your personal information, withdraw your consent, or get more information or a copy of this Privacy Policy contact:

InterGroup Privacy Officer

Mailing Address: 300-259 Portage Avenue, Winnipeg MB R3B 2A9

Telephone No.: 204-942-0654

E-mail: ig@intergroup.ca

17. Complaints

InterGroup has procedures in place to address and respond to complaints about how we handle your personal information. If you need assistance in making a complaint, let us know by contacting our Privacy Officer and someone will help you.

Once a complaint is filed, we will begin an investigation. The steps involved will include:

Recording the date the complaint was received and the nature of the complaint;
Sending an acknowledgment to the person who complained confirming that we received the complaint and will investigate;
Assigning someone to investigate; and
Once the investigation has been completed, documenting a summary of outcomes and recommendations.

If a complaint is valid, we’ll take steps to resolve it, such as updating policies or procedures if necessary. You will be informed of the investigation’s results.

18. Privacy Policy Changes

We may update this Privacy Policy due to changes in our services, our technology, or the law. If we make changes, we’ll let you know through the Services or some other way so you can review them before they take effect. For example, we may place a prominent notice on the Sites or e-mail you to let you know of an updated Privacy Policy.

If we make significant changes, like using your personal information in a new way or disclosing it to new third parties, we’ll give you at least 30 days’ notice.

If we need your express consent, we’ll ask for it. Otherwise, if you keep using our Services after we update this Privacy Policy, it means you agree to the new terms. If you don’t agree, you can stop using the Services or tell us that you want to end our business relationship.

Whenever we update this Privacy Policy, we will change the date at the top to show when the changes were made.