I. INTRODUCTION

The purpose of this privacy statement is to outline the practices and procedures of Shore Newman & Rose LLP. (the “Firm”) relating to the collection, disclosure, use and safeguarding of personal information. The Firm respects the privacy of personal information in all aspects of our business. We want everyone to know that we are responsible for the privacy of personal information of a variety of persons throughout the course of the services we provide.

II. DEFINITIONS

"Act" means the Personal Information Protection and Electronic Documents Act.

"consent" means the voluntary agreement with the collection, use and disclosure of personal information for authorized purposes. Consent can be either express or implied and can be provided directly by the person or by an authorized representative. Express consent can be given orally, electronically or in writing, and is your firm authorization. Implied consent is a common sense conclusion that consent has been obtained from a person's action or inaction.

"person" or "persons" means a natural person and includes a client of the Firm and any other person in which the Firm interacts in the course of its commercial activities.

"personal information" means any information about an identifiable person.

III. WHY YOUR PERSONAL INFORMATION IS COLLECTED, USED, DISCLOSED OR RETAINED

Based on the nature of our business, we regularly collect, use, disclose and retain personal information about persons in order to provide services to our clients. In order that all persons are fully informed, we are outlining the purposes for which the Firm collects, uses, discloses and retains personal information.

Thus, the purposes for which the Firm may collect, use, disclose and retain personal information about persons may include:

1. Providing competent services to our clients;
2. Fulfilling our client's requests for information, including for audit purposes and for the conduct of operations;
3. Complying with the law, regulatory requirements, and court orders;
4. Assessing and developing the Firm's business and operations to better service its clients.

At or before the time of collecting such information, the Firm will identify the purposes for which it is being collected. The collection of personal information will be limited to that which is necessary for the purposes identified by the Firm. Information shall be collected by fair and lawful means.

IV. WHAT KIND OF PERSONAL INFORMATION DOES THE FIRM COLLECT AND FROM WHERE IS IT COLLECTED?

The personal information collected by the Firm about you as a person, as applicable, may include, but is not limited to:

• Your home address, home telephone number, cell phone number, work number, email address, other contact information, employment history, salary, benefits, perquisites, and other related information;
• Financial information, banking information, social insurance number, medical information, tax history and other tax information, marital status, age, date of birth, country of residence, country of birth, net worth, credit history, liabilities, assets, etc.;
• Information required for security purposes, any information required by law, or any information required to satisfy our contractual or other obligations.

The Firm may gather personal information about you from a number of sources including:

• From you, including from applications or forms completed by you, interviews, face-to-face discussions, telephone communications, e-mail, internet, the Firm website and any other means of communications, whether verbal, written or otherwise;
• From third parties through enquiries we make to verify details provided to us, such as credit checks;
• Where applicable, from your agents, brokers, lawyers, intermediaries, and representatives as well as from government and other entities;

V. CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

The knowledge and consent of a person is required for the collection, use, or disclosure of personal information, except where otherwise not required under the Act. As a person, when you engaged our Firm to provide services or provided us with your personal information (i.e. financial information, etc.), you were understood to have provided the Firm with your implied consent to the Firm's collection, use, disclosure and retention of your personal information for the purposes identified to you under this statement (see part III). In determining the appropriate form of consent, the Firm will take into account the sensitivity of the personal information and the reasonable expectations of persons.

Personal Information will not, without the individual's consent, be disclosed to any individuals in our firm beyond those who are engaged in providing services to the client, except as required or permitted by law or under the Act.

You may withdraw your consent at any time, subject to any statutory or contractual exceptions or restrictions and reasonable notice. You should contact the Firm for more information at the address below.

VI. THE FIRM WILL LIMIT THE USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION

Your records are retained to document personal, confidential and business-related information about you and your relationship with the Firm. The Firm will use or disclose your personal information only for the purposes for which it is collected, except with the consent of the person or as required or permitted by law. The Firm shall retain personal information only as long as required to satisfy the purposes identified above where possible, to comply with any obligations specified in the Act, or other statutes, to meet any potential obligations, and to protect the interests of the Firm and its clients.

[NTD - The following sentence may be deleted if not applicable] - In accordance with applicable regulations, our client files may be periodically reviewed by inspectors and other firm personnel to ensure that we have adhered to professional and firm standards. File reviewers are required to maintain confidentiality of client information.

The Firm Website

The Firm web server anonymously logs requests from individual web browsers but is not related to any personal information. The information logged primarily consists of internet IP address, files that the person's browser has requested, the time of the request, browser type and computer type and page from which the person came. The Firm uses the above information to understand the number of visitors to its website, the type of information requested, and what problems, if any, may exist on the website. This information is used in aggregate and is not linked to any personally identifiable information. When someone visits a website, a cookie is placed on the individual's machine (if the individual accepts cookies) or is read if the person has visited the site previously. The web server does this as a matter of course and the information is not required to use the Firm website. An individual may turn cookies off in his or her browser and still use all the functionality of the Firm website.

VII. THE FIRM WILL ENSURE THE ACCURACY AND PROTECTION OF YOUR PERSONAL INFORMATION

The Firm will attempt to keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is used. In this regard, we expect that you will also participate and provide us with all updated personal information as required (especially contact information). In addition, the Firm maintains strict security systems to safeguard your personal information as is appropriate in respect of the sensitivity of that information. Unfortunately, on the Firm website, please note that no one can guarantee 100% security. If you have particular security concerns about certain personal information, please do not transmit information over the internet or email.

VIII. HOW YOU MAY ACCESS YOUR PERSONAL INFORMATION

Upon request, the Firm will make information about its policies and practices relating to the management of personal information readily available to persons. You may access your personal information that the Firm has in its possession, subject to any statutory exceptions or restrictions. To obtain access to your personal information, please make a written request to the Firm's CPO stating as specifically as possible what personal information you are requesting access to. You will be able to challenge the accuracy and completeness of the information disclosed and have it amended if appropriate. For more information on the procedures for doing so, please contact the CPO.

IX. WHAT YOU CAN DO IF YOU FEEL THIS STATEMENT HAS NOT BEEN FOLLOWED

If you believe that the Firm has improperly or without authorization collected, used, disclosed or retained personal information about you contrary to this statement, you must make a written complaint to the Firm's CPO. Your written complaint should set out as much detail as possible about your concerns.

X. ADDITIONAL INFORMATION

For more information, to request access or an amendment to your personal information, or to discuss a complaint, please write to, call or fax the CPO at: