At Cowle Law, in keeping with our obligations as legal professionals, we are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. This Policy Statement has been prepared to affirm our commitment to maintaining the privacy of our clients and others and to inform you of our practices concerning the collection, use and disclosure of Personal Information collected by the firm. Our obligations as legal professionals are governed, in part, by the Rules of Professional Conduct that govern each of our professionals as members of the Law Society of Ontario. These obligations apply to all professionals, employees, contractors and agents who provide services in connection with our delivery of legal and other services to our clients. Other applicable laws and internal Firm policies govern the protection of Personal Information of partners, associates and employees of Cowle Law. For the purposes of this Policy, “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. This policy does not cover any information, recorded in any form, about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”). Cowle Law retains the right to use Aggregated Information in any way that it determines appropriate. Using contractual or other arrangements, Cowle Law shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to Cowle Law as part of our delivery of products and services, protect that Personal Information in a manner consistent with the principles articulated in this Policy Statement.

Professional Relationship

As a general rule, all information concerning the business and affairs of a person or organization acquired (1) for the purpose of determining whether Cowle Law will enter into a professional relationship or (2) in the course of a professional relationship shall be held in strict confidence and not revealed to anyone unless expressly or implicitly authorized by the person or organization concerned. A professional relationship develops when Cowle Law agrees to be retained to provide services to a particular individual or organization. In order to protect their own interests, individuals or organizations should not send confidential information to Cowle Law until they have had a direct discussion with a professional at the firm regarding the retention of Cowle Law to provide legal services.

The Collection, Use & Disclosure of Personal Information

Your provision of Personal Information to Cowle Law means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to Cowle Law. Unfortunately, certain services can only be offered if you provide Personal Information to Cowle Law. Consequently, if you choose not to provide us with any required Personal Information, Cowle Law may not be able to offer you those services. Cowle Law collects only such information from individuals or organizations as is required for the purposes of providing services or information to them. Cowle Law does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no Personal Information is collected about an individual, without first obtaining the consent of the individual to the collection, use and dissemination of that information. Personal Information will be collected, to the extent possible, directly from the individual concerned. Unless in the context of providing legal or other services, Cowle Law does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if it discovers that it is has been provided by a minor. Cowle Law may disclose Personal Information to organizations that perform services on behalf of the Firm. Personal Information will only be provided to such organizations if they agree to use such information solely for the purposes of providing services to Cowle Law and under the instruction of Cowle Law and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy. Personal Information may also be subject to transfer to another organization in the event of a merger or change of ownership of all or part of Cowle Law. This will occur only if the parties have entered into an agreement under which the collection, use and disclosure of the information is restricted to those purposes that relate to the business transaction, including a determination whether or not to proceed with the business transaction, and is to be used by the parties to carry out and complete the business transaction. Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Cowle Law is obliged to disclose information without consent. Such circumstances may include:

• Where required by law or by order or requirement of a court, administrative agency or another governmental tribunal;
• Where Cowle Law believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• Where it is necessary to establish or collect monies owing to Cowle Law;
• Where it is necessary to permit Cowle Law to pursue available remedies or limit any damages that Cowle Law may sustain; or
• Where the information is public or accessible on a public record.

Retention

Cowle Law keeps Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for Cowle Law’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form. Currently, the principal places in which Cowle Law holds Personal Information are the offices of Cowle Law and nearby municipalities where off-site storage facilities may be located.

Security

Cowle Law endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. Cowle Law further protects Personal Information by restricting access to it to those employees that the management of Cowle Law has determined need to know that information in order that Cowle Law may provide its services. In terms of communicating Personal Information to Cowle Laws, you may wish to note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted. As do many organizations, Cowle Law attempts to strike a reasonable balance between security and convenience. In communicating with clients and others, Cowle Law often requests the right to use a method of communication that is less secure than some of its less convenient alternatives. An example of this is e-mail. At this time, when we use e-mail, it may be sent as unencrypted plain text. We do this because Cowle Law believes that many of our clients and others cannot readily process encrypted e-mail. This is done for their convenience but has the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail

Cowle Law Web Site

Cowle Laws provides clients and others with general access to public web sites. Our Web servers track general information about visitors such as their domain name and time of visit. Cowle Law’s Web servers also collect and aggregate information regarding which pages are being accessed as well as information volunteered by visitors through online surveys or subscriptions to electronic newsletters. This information is used internally, only in aggregate form, to better serve visitors by helping us to: Manage our sites Diagnose any technical problems Improve the content of our Web site During the course of an individual’s use of the Internet, he or she will learn of the common use of “cookies.” “Cookies” are files or pieces of information that may be stored in a computer’s hard drive when an individual visits a web site. Most Internet browsers are initially set to accept cookies. If you do not wish to accept cookies, you can set yours to refuse cookies or to alert you when cookies are being sent

Amendment of Practices and This Policy

This statement is in effect as of April 30th 2019. Cowle Law will from time to time review and revise its privacy practices and this Policy Statement. In the event of any amendment, an appropriate notice will be posted on Cowle Law’s web site. Policy changes will apply to the information collected from the date of posting of the revised Policy Statement to Cowle Law’s web site as well as to existing information held by Cowle Law.

Questions

In the event an individual has questions about (a) access to Personal Information; (b) the collection, use, management or disclosure of Personal Information; or (c) this Policy Statement, that person should e-mail bruce@napaneelawyer.com, the Firm’s Chief Privacy Officer, L. Bruce Cowle. Where obliged or permitted to disclose information without consent, Cowle Law will not disclose more information than is required