Privacy Policy

FULLER LANDAU LLP AND ALL OF ITS RELATED ENTITIES
( “FULLER LANDAU”)

Statement of Principle

Fuller Landau (also referred to as the “firm”) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy. If you have any questions about the firm’s privacy policies and practices, the firm’s Privacy Officer can be reached by email at privacyofficer@fullerlandau.com, by phone at 416-645-6500, or by letter to 151 Bloor Street West, 12th Floor, Toronto, Ontario, M5S 1S4.

Your Privacy Rights

From January 1, 2004, all businesses engaged in commercial activities must comply with the Canadian government’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information that PIPEDA incorporates. These obligations extend to all Canadian businesses including Fuller Landau. PIPEDA gives you rights concerning the privacy of your personal information. Fuller Landau is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our staff about our policies and practices.

Why Does Fuller Landau Need Personal Information?

Fuller Landau provides services and products to a wide range of clients. To effectively complete engagements for our clients, the partners and staff involved in the engagement need access to the types of personal information noted below. As part of our service commitment, we also produce direct marketing materials concerning our services and products that we feel will be of interest to you.

What personal information do we collect?

Personal information is any information that identifies you, or by which your identity could be deduced. If we did not collect and use your personal information, we would be unable to provide our products and services to you.

How do we collect your personal information?

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible, we collect your personal information directly from you in the ordinary course of our business. Sometimes we may obtain information about you from other sources, for example, from Canada Revenue Agency.

Consent

In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing as evidenced in our engagement letter, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.

Use of Your Information

We use your personal information to provide our products and services to you; to administer your account with us; and to include you in any direct marketing activities. If you tell us that you no longer wish to receive information about our products or services, we will not send any further material.

Fuller Landau does not disclose your personal information to any third party to enable them to market their products or services. For example, we do not provide our client mailing lists to third parties.

Disclosure of your Personal Information

Fuller Landau will disclose your personal information under circumstances such as:

• When we are required or authorized by law to do so;
• When you have consented to the disclosure;
• When the products or services we are providing to you require us to give your
ttinformation to third parties your consent will be implied, unless you tell us otherwise;
• Where it is necessary to establish or collect payment;
• If we engage a third party to provide products or services to us [such as using an
ttoutside service bureau to process tax returns or engaging a record retention
ttagency to store prior year records], the third party is bound by our privacy policy;
• And if the information is already publicly known.

Updating Your Information

Since we use your personal information to provide products and/or services to you, it is important that the information be as accurate and up-to-date as possible.
If, during the course of doing business with us, any of your information changes, please inform us so that we can make any necessary changes.

Is Your Personal Information Secure?

Fuller Landau takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• Premises security;

• Restricted file access to personal information;

• Deploying technological safeguards like security software and firewalls to prevent
. hacking or unauthorized computer access;

• Internal password and security policies.

Access to Your Personal Information

You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to reasonable charges.

Correcting Errors

If Fuller Landau holds information about you and you can establish that it is not accurate, complete and up-to-date, Fuller Landau will take reasonable steps to correct it.