PRIVACY POLICY

Fortis Muyal LLP is committed to maintaining the accuracy, security and privacy of Personal Information in accordance with applicable legislation. This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our clients, service providers and other individuals ("you").

Consent

BY SUBMITTING PERSONAL INFORMATION TO FORTIS MUYAL LLP, (HEREINAFTER “FMLLP”) YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting FMLLP's Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide FMLLP or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

Below is a list of questions and subjects covered in this Privacy Policy statement:

• What is Personal Information?
• Why do we collect your Personal information?
• How do we collect your personal information?
• To whom do we disclose your Personal Information?
• When and how do we obtain your consent?
• What Limiting Principles do we adopt?
• Where do we store your Personal Information?
• How may you obtain access to your Personal Information?
• How do we protect your Personal Information?
• Privacy and our Website
• Changes to the Privacy Policy
• How long will we utilize, disclose or retain your Personal Information
• How do you know that the Personal Information we have on you is accurate?
• What if the Personal Information we have on you is inaccurate?
• How fast will we respond to your written requests?
• Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or Practices?
• How do we know that it is really you requesting your Personal Information?
• Further Information.

What is Personal Information?

Personal Information is generally any information about an identifiable individual. The type of personal information FMLLP collects, uses and discloses may include your name, age, mailing address, residential phone numbers or email address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship matters, penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and other benefits, medical records, tax records, and security clearances. Personal Information however may not include your name, business title or business address and business telephone number in your capacity as an employee of an organization/enterprise.

Why do we collect your Personal Information?

In general, FMLLP collects, uses and discloses Personal Information about our clients and service providers in order to provide our clients with professional legal services. More specifically, we collect, use and disclose your Personal Information for the following purposes:

• to establish and manage client relationships, provide legal advice, perform legal services, fulfil legal duties, and avoid conflicts of interest. This may include the sharing of Personal Information by and between FMLLP personnel and affiliated companies and partnerships for such purposes;
• to share Personal Information to and from third parties for the purpose of providing legal services. Such third parties may include opposing parties; parties in interest; opposing, foreign and other counsel and advisors; witnesses; decision-makers; and experts;
• to consider whether FMLLP should establish a commercial relationship with clients, suppliers and other third parties, including to evaluate credit standing and to match credit bureau or credit reporting agency information;
• to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfil contractual obligations;
• to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
• to develop, enhance, market, sell or otherwise provide FMLLP's products and services;
• to market, sell or otherwise provide products and services of third parties with whom FMLLP has a commercial relationship;
•  to distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers;
• to develop and manage our knowledge-management precedent systems and databases;
• to develop and manage FMLLP's business and operations;
• to detect and protect FMLLP and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with FMLLP policies and contractual obligations;
• to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving FMLLP;
• as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
•  for any other purpose to which you consent.

How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means, including retainer, general correspondence, faxes, emails and telephone inquiries. We often collect Personal Information from you or from third parties and as agents on behalf of our clients, where we have obtained the requisite consent to do so (for example, upon a client's instructions) or as otherwise permitted by law. Third parties include, as examples, witnesses, service providers, references and other persons that we need to contact to provide services to and for clients or for administrative or management requirements.

To whom do we disclose your Personal Information?

From time to time, FMLLP may disclose your Personal Information to:

• service providers, including an organization or individual retained by FMLLP to perform functions on its behalf, such as marketing, data processing, document management and office services;
• an organization or individual retained by FMLLP to evaluate your creditworthiness or to collect debts outstanding on an account;
• a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements; or
• a person who, in the reasonable judgment of FMLLP, is providing or seeking the information as your agent;
• any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

When supplementary disclosure is required, we will identify (at the time we collect such information from you and obtain the requisite consent to such disclosure, unless otherwise permitted by law) the other persons/organizations/enterprises and the other purposes to whom and for which disclosure may occur.

When and how do we obtain your consent?

Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally or in writing. We will obtain your express consent as often as possible. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided Personal Information to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you at home. Except when otherwise permitted by law, we will only use the information for the purpose for which it was given. From time to time, we may collect, utilize or disclose your Personal Information based on your consent and as otherwise permitted by law.

When your consent is required, you can withdraw consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations), and upon providing us with a 30-day notice. However, the withdrawal of your consent may impact on our ability to serve you and to maintain our relationship.

In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without your knowledge or consent. These circumstances include (where applicable): Personal Information which is subject to solicitor-client privilege; information on individuals which is publicly available; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of any agreement or a contravention of a law; to comply with a subpoena, warrant, court order or as required or otherwise permitted by law.
What limiting principles do we adopt?

FMLLP only collects the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

FMLLP does not, as a condition of supplying a service to you, or of establishing, managing or terminating an employment relationship, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with its obligations under applicable law.

We do not use or disclose your Personal Information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

Where do we store your Personal Information?

Your Personal Information is stored in secured locations and on servers controlled by FMLLP.

How may you obtain access to your Personal Information?

Upon your written request, subject to certain exceptions, FMLLP will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. Access requests should be sent to our Chief Privacy Officer, using the contact information below.

How do we protect your Personal Information?

To help protect the confidentiality of your Personal Information, FMLLP employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. For instance, we operate secure data networks protected by industry standard firewall and password protection systems.

Privacy and our Website

• Cookies - When an individual visitor accesses the FMLLP website, we may use a browser feature called a 'cookie' to collect information such as the type of Intemet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor's browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
• Online Communications - In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, participating in a seminar or other event, and participating in surveys. If you are known to FMLLP as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.
• E-Mail Communications - Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of FMLLP and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from FMLLP.
• Links - Our website may contain links to other websites which are provided for your convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than FMLLP, and FMLLP has no responsibility for such third party websites.

Changes to the Privacy Policy

FMLLP reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our website and make such revised policy and changes available upon request to the FMLLP Chief Privacy Officer. However, FMLLP will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

How long will we utilize, disclose or retain your Personal Information?

FMLLP may keep a record of your Personal Information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as required or otherwise permitted by law.

How do you know that the Personal Information we have on you is accurate?

We will use reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. In order to help us maintain and ensure that your Privacy Information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to us.

What if the Personal Information we have on you is inaccurate?

You can, at any time, challenge the accuracy or completeness of the Personal Information we have on you, subject to the exceptions provided by the applicable law. If you successfully demonstrate that the Personal Information we have on you is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties to whom we have communicated your Personal Information.

How fast will we respond to your written requests?

We will make every reasonable effort to respond to each of your written requests not later than thirty (30) days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate Privacy Authority in respect of this time limit.

Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or Practices?

Access to your Personal Information contained in a file is free of charge. However, a reasonable charge may be required when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.

Further Information

FMLLP has appointed Moses Muyal as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on FMLLP's privacy practices, please contact the FMLLP Chief Privacy Officer at:

Fortis Muyal LLP
Lawyers
Chief Privacy Officer
Suite 409
15 Wertheim Court
Richmond Hill
Ontario, CANADA
L4B 3H7

Tel.: (905) 731-1911
Fax.: (905) 731-1913