What Is Personal Information?
In this Privacy Policy, "Personal Information" means information that specifically identifies a Client as an individual and is provided to, or collected by, WILLSON LEWIS LLP and its staff or by WILLSON LEWIS LLP's agents, associates, and affiliates on WILLSON LEWIS LLP's behalf (collectively, the "WILLSON LEWIS LLP Group"). Personal Information however, does not include your name, business title or business contact information in your capacity as an employee.

Why WILLSON LEWIS LLP Collects Personal Information
WILLSON LEWIS LLP collects and uses Personal Information for the following purposes:

• Providing legal services and products to the Client;
  
  
• Advising Clients of the legal services provided by WILLSON LEWIS LLP, as well as, ongoing developments of the law;
  
  
• Auditing the services provided to our Clients;
  
  
• Administration, billing, accounting and collection issues related to a Client's account with WILLSON LEWIS LLP;
  
  
• Compliance with all municipal, provincial, federal and other applicable laws; and
  
  
• Such other specific purposes which are communicated to the Client by a member of the WILLSON LEWIS LLP Group before collection of such Personal Information.

How Do We Collect Personal Information?
Wherever possible we collect your personal information directly from you, at the start of a retainer and in the course of our representation. Sometime we may obtain information about you from other sources, for example, from:

• a Client's insurance company;
  
  
• a Client's real estate agent in a property transaction;
  
  
• from a government agency or registry;
  
  
• A Client's employer, at the Client's request; and
  
  
• A Client's accountant, banker, financial advisor or other professional.

The most common method we use to obtain a Client's consent is by way of the Client's oral consent as confirmed by a retainer letter or, where applicable, by Client intake questionnaire. Where practicable, we may also obtain a Client's consent through oral communications. You may also consent by implied means such as when you have previously provided Personal Information to us and continue to use our legal services on other matters or where you provide us with your personal telephone number so that we can contact you at home or place of work.

Our Clients may withdraw their consent by written notice to us at any time, subject to any legal or contractual restrictions and reasonable notice. A Client's refusal to provide, or subsequent withdrawal of, his or her consent may affect WILLSON LEWIS LLP's ability to provide the Client with legal services. A member of WILLSON LEWIS LLP will inform the Client of the implications of such withdrawal. To withdraw consent, a Client should contact the Chief Privacy Officer in writing at:

Willson Lewis LLP
67 Mowat Avenue, Suite 346
Toronto, Ontario, M6K 3E3
Attn: Privacy Officer
Email: PrivacyOfficer@willsonlewis.com

Use and Disclosure of Personal Information
We will use a Client's Personal Information to provide legal advice and services to the Client, to administer our database, to include Clients in direct marketing activities and for the other uses described above under the heading "Why WILLSON LEWIS LLP Collects Personal Information". Under certain circumstances, WILLSON LEWIS LLP will disclose a Client's personal information to third parties. Specifically, Personal Information may be used, shared and disclosed to, from, or with, the members of the WILLSON LEWIS LLP Group, witnesses in a litigation proceeding, experts retained on a Client's behalf, private investigators, agents retained on behalf of a Client, credit reporting agencies, credit bureaus, as well as such other third parties as are necessary to facilitate the matter for which the Client has retained our office and provided its consent.

Under certain circumstances WILLSON LEWIS LLP may disclose Personal Information where:

• required or authorized by law to do so, for example if a court issues a subpoena;
  
  
• a Client has consented to the disclosure;
  
  
• when the legal services WILLSON LEWIS LLP is providing to a Client requires us to give Personal Information about a Client to a third party (for example, to a lender in a real estate mortgage transaction) the Client's consent will be implied, unless the Client tells us otherwise;
  
  
• where it is necessary to establish or collect fees;
  
  
• if WILLSON LEWIS LLP engages a third party to provide administrative or support services to us (such as computer back-up services, shredding or archival file storage) and the third party is bound by our Privacy Policy;
  
  
• expert witnesses on behalf of a Client require the information;
  
  
• if we retain other law firms on behalf of a Client; or
  
  
• if the information is already publicly known.

WILLSON LEWIS LLP will retain Personal Information only for so long as it is needed to fulfill the purposes for which it was obtained and to meet our professional requirements as set out by the Law Society of Upper Canada and/or any other legal requirement, statutory or otherwise, from time to time.

Accuracy
WILLSON LEWIS LLP strives to ensure that a Client's Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used.

Safeguards
WILLSON LEWIS LLP endeavours to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Clients' Personal Information in the care of the WILLSON LEWIS LLP.

Accountability, Openness and Client Access
WILLSON LEWIS LLP is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer to oversee our efforts to comply in all material respects with applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer (the "Privacy Team") address and investigate questions or concerns regarding a Client's Personal Information.

To reach the Chief Privacy Officer or a member the Privacy Team, please call 416-534-9504 or e-mail: PrivacyOfficer@willsonlewis.com. A copy of this Privacy Policy and any future updates or amendments is available at www.willsonlewis.com.

WILLSON LEWIS LLP will provide a Client access to their Personal Information. The Client may correct or amend any inaccuracies in the Client's Personal Information. WILLSON LEWIS LLP has the right to refuse a request for access to Personal Information if:

• The information is protected by legal privilege;
  
  
• Granting access would reveal confidential commercial information;
  
  
• Doing so would reasonably be expected to threaten the life or security of another individual;
  
  
• The information was collected for purposes related to the detection and prevention of fraud;
  
  
• The information was generated in the course of a formal dispute resolution process;
  
  
• The information would likely reveal personal information about another individual;
  
  
• The request is vexation or frivolous;
  
  
• The information would prejudice negotiation with you; or
  
  
• To protect our firm's rights and property.

Challenging Compliance
Clients are encouraged to discuss any privacy issues with the lawyer handling their matter, the Managing Partner, the Chief Privacy Officer or a member of the Privacy Team.

Changes To This Privacy Policy
WILLSON LEWIS LLP will from time to time review and revisit privacy practices and this Privacy Policy. In the event of any material amendment, an appropriate notice will be posted on WILLSON LEWIS LLP's Web site. All Clients are encouraged to contact WILLSON LEWIS LLP to establish if any updates have been made to this Privacy Policy, which can be ascertained by the date listed at the top of this Privacy Policy. All updates and amendments to this Privacy Policy can be found at www.willsonlewis.com.

WILLSON LEWIS LLP Web site
Our Web site may contain links to other sites, which are not governed by this Privacy Policy. On our Web site, like most other commercial Web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

Communicating With Us
We recognize that convenience and quick access to advice must be balanced with security needs. We use many different means to communicate with clients, some of which are more convenient such as e-mail. Our emails are sent with industry standard 128 bit encryption. Such encryption however does not guarantee privacy and security as encrypted messages can nonetheless be subject to interception and translation. If you do not wish us to communicate with you by e-mail, please speak with the lawyer handling your matter about alternative arrangements.