HOFFER ADLER LLP PRIVACY POLICY

Introduction
This Policy applies to the collection and use of personal information by Hoffer Adler LLP and Jahl Management Inc. Jahl Management Inc. is a private corporation controlled by the partners of Hoffer Adler LLP which provides management services to Hoffer Adler LLP. References hereafter to "Hoffer Adler LLP", "we", "our" or "us" include each of Hoffer Adler LLP and Jahl Management Inc., as the case may be.

"Personal Information" for purposes of this Policy includes information about our clients, service providers, and other individuals, but does not include information with respect to corporate or commercial entities. It also does not include business contact information or publicly available information exempted under the Personal Information Protection and Electronic Documents Act.

1. Accountability
Hoffer Adler LLP manages personal information in accordance with this Policy. Lloyd Hoffer is our Privacy Officer and in that capacity he is responsible for dealing with privacy inquiries or complaints.

2. Purposes for Which Personal Information is Collected and Used
Hoffer Adler LLP collects, uses, and discloses personal information for purposes lawfully permitted, authorized and/or required and including for the following purposes:

• to provide legal advice and to perform legal services

• to comply with legal and regulatory obligations

• to establish and manage our relationships with our clients and with our suppliers, consultants and insurers

• for purposes of billing for services, processing payments, and collecting debts owed to Hoffer Adler LLP

• for providing clients and prospective clients with occasional news or updates regarding legal developments or services

• for other purposes (which may be agreed) in the course of our relationships

3. Consent
Hoffer Adler LLP may collect, use, and disclose personal information where permitted, authorized or required by law to do so, and otherwise with consent. Consent may be implied or express, and may be given through an authorized representative such as a lawyer, or agent. The provision of personal information to us constitutes consent to the collection, use and disclosure of that personal information in accordance with this Policy. Consent may be withdrawn on reasonable written notice to us; however, in that event, our ability to continue to provide legal services for which personal information is necessary may be compromised.

4. Limits on the Collection of Personal Information
Hoffer Adler LLP collects personal information only as permitted, authorized or required by law and in accordance with this Policy.

5. Limits on the Use, Disclosure, and Retention of Personal Information
Hoffer Adler LLP uses and discloses personal information for the purposes set out in this Policy. Where personal information is no longer required for the purpose for which it was collected, it may be retained for a reasonable period of time thereafter, depending upon the nature of the information and the purpose for which it was used, in order that it may remain available for disclosure to persons entitled to access it, or for future use by us or our clients in the event that subsequent events make it necessary again for the purposes for which it was first collected (as, for example, where legal proceedings thought to be complete are subsequently re-activated). Personal information gathered in the course of legal proceedings or services will typically be maintained at least for a number of years following completion of the services or proceedings, unless returned to our clients or forwarded to other solicitors at our client s direction. Upon expiry of a reasonable period of retention, reasonable steps are taken to destroy, erase, or render anonymous the personal information.

6. Accuracy
Hoffer Adler LLP attempts to collect and maintain personal information on a basis as accurate, complete, and up to date as is necessary for the purposes for which it is collected. Often we will be relying on the party providing us with that information to ensure it is accurate and complete at the time it is provided. Where it is appropriate for us to do so, we will endeavour to correct any errors in our records when these are brought to our attention.

7. Safeguards
All of our partners, associates and staff are familiar with this Privacy Policy and are responsible for helping to observe it. To protect personal information, we keep most documents on our premises. Our premises are kept secured at all times when the office is closed. Where documents are required to be stored off site for reasons of storage or otherwise, we use a reputable storage company which is familiar with and respects our need for confidentiality. Similarly, where access to our information may be required by third party professionals for technological, accounting, legal, insurance, or regulatory purposes, only required information is disclosed and only for that period of time required to fulfill our needs or obligations. Where we do use outside consultants, we choose our consultants whom we consider trustworthy and whom we believe will respect our confidentiality concerns.

8. Openness
Questions or concerns about our Privacy Policy and our practices may be raised with Lloyd Hoffer, our Privacy Officer.

9. Individual Access
Individuals may request access to their personal information in the possession of Hoffer Adler LLP and information about the use and disclosure of that personal information by sending a request in writing to Lloyd Hoffer, Privacy Officer. Hoffer Adler LLP will make reasonable efforts to provide either the requested information within a reasonable period of time or an explanation of why any requested information will not be provided if there are legal or other reasons why disclosure cannot be made or is not required to be made. Hoffer Adler LLP will endeavour to provide such information or explanation at minimal cost to the requesting individual, but may charge a reasonable fee to defray time and expense in doing so, where appropriate.

10. Compliance
Individuals with concerns or complaints regarding Hoffer Adler LLP s compliance with its privacy obligations may address those concerns or complaints to Lloyd Hoffer, Privacy Officer.

11. Change
Hoffer Adler LLP may review and modify this Privacy Policy from time to time.

12. Contact

Lloyd Hoffer, Privacy Officer
Hoffer Adler LLP
Suite 300
425 University Avenue
Toronto, Ontario M5G 1T6

416-977-2555
lhoffer@hofferadler.com

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