DELANEY'S LAW FIRM'S POLICY ON THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION ("Privacy Policy")

Delaney's Law Firm recognizes the importance of confidentiality and the protection of personal information. This privacy policy explains how we use and protect personal information we hold, whether it relates to our clients, potential clients, staff, job candidates, partners, former associates or partners, consultants, or third party service providers.

Personal information is information about an identifiable individual or information that permits an individual to be identified. It does not include business contact information, such as name, title, business address and business telephone number when used for business communications.

OBJECTIVE & SCOPE OF POLICY

Consistent with our obligations as professionals, Delaney's Law Firm is dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. This Privacy Policy 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 (as defined below) collected by Delaney's Law 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 Upper Canada. 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 Delaney's Law Firm.

For the purposes of this Privacy 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 Privacy 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"). Delaney's Law Firm retains the right to use Aggregated Information in any way that it reasonably determines is appropriate.

Using contractual or other arrangements, Delaney's Law Firm shall ensure that agents, contractors and third party service providers, who may receive Personal Information in the course of providing services to Delaney's Law Firm as part of our delivery of products and services, protect that Personal Information in a manner consistent with the principles articulated in this Privacy Policy and applicable laws.

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 Delaney's Law Firm 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 Delaney's Law Firm 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 Delaney's Law Firm until they have had a direct discussion with a professional at the firm regarding the retention of Delaney's Law Firm to provide legal services.

THE COLLECTION, USE & DISCLOSURE OF PERSONAL INFORMATION

Your provision of Personal Information to Delaney's Law Firm 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 Delaney's Law Firm. Unfortunately, certain services can only be offered if you provide Personal Information to Delaney's Law Firm. Consequently, if you choose not provide us with any required Personal Information, Delaney's Law Firm may not be able to offer you those services.

Delaney's Law Firm collects only such information from individuals or organizations as is required for the purposes of providing services or information to them. We do not indiscriminately collect or retain information. We typically collect personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Our reason for collecting personal information about job candidates, staff, partners and consultants is to establish and maintain the employment, contractual or partnership relationship. The purposes for collecting personal information about our clients and prospective clients is primarily to provide legal services and representation, to maintain client relationships, communicate with our clients, maintain mailing lists and avoid conflicts of interest. As appropriate, Delaney's law firm will ask for specific consent to collect, use and disclose personal information. This may be in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information. Personal information supplied to us is confidential and we do not disclose the information to any third party except with actual implied consent, or as permitted or required by law.

Delaney's Law Firm does not sell, trade, barter or exchange for consideration any Personal Information it has obtained.

Unless in the context of providing legal or other services, Delaney's Law Firm 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.

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 Delaney's Law Firm. 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 Delaney's Law Firm 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 other governmental tribunal;

• Where Delaney's Law Firm 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 Delaney's Law Firm;
• Where it is necessary to permit Delaney's Law Firm to pursue available remedies or limit any damages that Delaney's Law Firm may sustain; or
• Where the information is public.
• Where obliged or permitted to disclose information without consent, Delaney's Law Firm will not disclose more information than is required.

ACCURACY

Delaney's Law Firm endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which Delaney's Law Firm uses that information.

RETENTION

Delaney's Law Firm 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 Delaney's Law Firm' purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.

Delaney's Law Firm does allow certain authorized third party providers to track and store certain information about visitors to Delaney's Law Firm web sites (namely domain names, IP addresses and page views as described below) and such information will be stored outside of Canada if the third party provider is located outside of Canada. Individuals that use and access Delaney's Law Firm web site hereby acknowledge and agree that such information obtained by such third party providers located in countries other than Canada may be accessed by the courts, law enforcement or national security authorities of such country.

ACCESSING YOUR PERSONAL INFORMATION

Delaney's Law firm will generally inform you if we are holding personal information about you, as well as details about the personal information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to personal information may be denied if required or authorized by law, including in accordance with the requirements of the client confidentiality or solicitor-client privilege. If the request for access is denied, Delaney's Law Firm will provide an explanation of the reasons for the refusal. If you choose to withdraw your consent to the continued collection, use or retention of your personal information, we will explain the consequences of such withdrawal.

SECURITY

Delaney's Law Firm has taken steps 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.

Delaney's Law Firm further protects Personal Information by restricting access to it to those individuals that the management of Delaney's Law Firm has determined need to know that information in order that Delaney's Law Firm may provide its services.

In terms of communicating Personal Information to Delaney's Law Firm, 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, Delaney's Law Firm attempts to strike a reasonable balance between security and convenience. In communicating with clients and others, Delaney's Law Firm 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 Delaney's Law Firm believes that many of our clients and others cannot readily process encrypted e-mail. This is done for their convenience but we expect that our clients and others understand that if misrouted or intercepted, unencrypted email could be read more easily than encrypted e-mail.

DELANEY'S WEB SITE

The Delaney's Law Firm website is designed to supply brief summaries of certain areas of the law, procedural information as well as some commentary and FAQs. All content and comments provided are, of necessity, brief and are not intended to be relied upon as legal advice. We encourage you to contact any of the lawyers listed for further details or advice in the context of a particular situation.

Delaney's Law Firm provides clients and others with general access to public web sites and restricted access to extranets. Our Web servers and authorized third party providers track general information about visitors such as their domain name, IP address and time of visit. Delaney's Law Firm' 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 DELANEY'S LAW FIRM PRACTICES AND THIS PRIVACY POLICY

This Privacy Policy is in effect as of January 1, 2010. Delaney's Law Firm will from time to time review and revise its privacy practices and this Privacy Policy. In the event of any amendment, an appropriate notice will be posted on Delaney's Law Firm web site. Policy changes will apply to the information collected from the date of posting of the revised Privacy Policy to Delaney's Law Firm' web site as well as to existing information held by Delaney's Law Firm.

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 Privacy Policy, that individual should e-mail bryan@delaneys.ca.