Privacy Policy

Last revised: April 11, 2018

At PwC Law LLP, we are committed to protecting your privacy and safeguarding your personal, business and financial information. This Privacy Policy applies to PwC Law LLP.

The purpose of this Privacy Policy is to inform you about the types of Personal Information, as defined below, that PwC Law LLP collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

As we are a national organization, this Privacy Policy is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and its regulations ("PIPEDA") as well as applicable provincial privacy legislation and regulations, including but not limited to, the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta), the Personal Health Information Protection Act (Ontario) and An Act respecting the protection of personal information in the private sector (Quebec). We also note that in addition to these laws, we continue to be subject to the confidentiality rules of the Institutes of Chartered Accountants.

We will treat your Personal Information in a manner consistent with our Privacy Policy, unless we have your consent to treat it differently. This Privacy Policy applies to any information we collect or receive about you, from any source.

From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the top of this page.

The following topics will be covered in this Privacy Policy:

1. What is Personal Information?
2. How do we collect your Personal Information?
3. Where do we store your Personal Information?
4. How do we use your Personal Information?
5. To whom do we provide your Personal Information?
6. When and how do we obtain your consent?
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
8. How long will we utilize, disclose or retain your Personal Information?
9. How can you review your Personal Information that we have collected, utilized or disclosed?
10. How do you know that the Personal Information we have on you is accurate?
11. What if the Personal Information we have on you is inaccurate?
12. How fast will we respond to your written requests?
13. Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or practices?
14. How do we know that it is really you requesting your Personal Information?
15. What safeguards have we implemented to protect your Personal Information?
16. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

1. What is Personal Information?

"Personal Information" is any information that is identifiable with you, as an individual. This information may include, but is not limited, to your name, mailing address, telephone number, email address, Internet Protocol (“IP”) address, age, gender, marital status, health information, financial status, credit card information and credit history. Personal Information, however, does not include your name, business title or business address or business telephone number in your capacity as an employee of an organization.

2. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means (for example, when you engage us to provide services, use the PwC Law LLP website or speak to a PwC Law LLP representative). We collect Personal Information directly from you and, or indirectly from third party service sources as permitted by law. In addition, we may collect information about you from sources such as financial institutions, insurance companies, government agencies, accountants in tax related or other professional matters, witnesses in litigation matters, government agencies or registries, other professional advisors or credit bureaus.

From time to time, you may voluntarily provide PwC Law LLP with unsolicited personal information (e.g. by providing personal information through the PwC Law LLP websites). If you do wish to provide such information for any reason, you consent to PwC Law LLP using that information in the ways described in this Privacy Policy or as described at the point where you choose to disclose this information. When providing PwC Law LLP with unsolicited information, we ask that you not provide any sensitive information (e.g. personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information) unless you provide us with explicit consent to collect this information from you.

With respect to our websites, PwC Law LLP may use cookies, log files and web beacons to collect information regarding the use of the websites. Generally, this information is non-identifiable and would likely not be considered Personal Information.

Cookies: Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is PwC Law LLP’s policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our Web sites.

Log files: In order to properly manage our website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.

Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a "single-pixel GIF" or "web beacon." Web beacons allow our third-party tracking tools, Adobe Analytics, Google Analytics and Oracle Marketing Cloud to gather information such as the IP address of your computer, the time the material was viewed and the type of Internet browser used to access the page. This information is tracked on the third party tracking tools' servers and reported in aggregate to our webmasters. If you are concerned about the use of Web beacons you can turn off your browsers' cookies. This action will prevent Web beacons from tracking your specific activity; however, the Web beacon may still record a visit from your IP address.

Marketing Automation: In order to provide you with the most personalized experience and give you access to products and services that are most relevant to you, PwC Law LLP uses marketing automation tools such as Oracle Eloqua to deliver targeted marketing campaigns across multiple PwC Law LLP platforms (e.g. via web, email, mobile, etc.) and create customer profiles by tracking your behavior and preferences while using PwC Law LLP platforms. All of PwC Law LLP’s electronic marketing activities are done in accordance with applicable legislation, including Canada’s Anti-Spam Legislation.

Children’s Privacy: PwC Law LLP understands the importance of protecting children’s privacy, especially in an online environment such as at our website. The PwC Law LLP website covered by this Privacy Policy is not intentionally designed for or directed at children 13 years of age or younger. It is PwC Law LLP’s policy never to knowingly collect or maintain information about anyone under the age of 13.

User-supplied information: If you fill out the contact form on this website, we will ask you to provide some personal information (such as e-mail address, name, phone number and state). We only require that you provide an e-mail address on the contact form. Further, if chat is available through this site, you may be asked to provide information if you participate in an online chat. Please do not submit any confidential, proprietary or sensitive personally identifiable information (e.g. Social Security Number; date of birth; driver’s license number; or credit card, bank account or other financial information) (collectively, “Sensitive Information”). If you submit any Sensitive Information, you do so at your own risk and we will not be liable to you or responsible for consequences of your submission. Information that you provide to us through the contact form or an online chat will be used so that we may respond to your inquiry. We may also use information you provide to us to communicate with you in the future. If you do not wish to receive such communications, you may opt out (unsubscribe), as described in further detail below.

3. Where do we store your Personal Information?

Personal Information provided to us by our clients is primarily stored on servers in Canada. However, except where restricted by contractual arrangements or legal requirements applicable to specific clients, PwC Law LLP also may leverage the services of select service providers. Personal Information that is "in the cloud" may be stored on multiple servers in a number of locations around the world. Rest assured that PwC Law LLP has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.

4. How do we use your Personal Information?

We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

• to assess whether we can act for you, including to avoid conflicts of interest;
• to provide you with advice and legal information and services;
• to assess client eligibility for credit;
• to invoice and collect payment for professional services provided by us to you;
• to research, develop, manage, protect and improve our business;
• to gather your opinion and feedback through surveys;
• to develop and maintain our relationship with you and communicate with you;
• to process your application for employment and resume;
• to advise you about new products and services that may be of interest to you (Please note that in accordance with Canada’s Anti-Spam Legislation, you can choose not to receive any electronic marketing communications from us by clicking the “opt out” function contained in all PwC electronic communications. You may choose not to receive any direct mail from us by contacting our Chief Privacy Officer as indicated in the “Contact Us” section below);
• to manage our business, including fulfilling contractual obligations and auditing our operations;
• to fulfill our legal and professional obligations, including client identification rules and other requirements of applicable provincial law societies;
• to prevent fraud and/or negligence; and
• such other uses as may be permitted or required by applicable law.

We identify the purposes for which we use your Personal Information at the time we collect such information from you, and obtain your informed, freely given and unambiguous consent prior to each specific use. When you provide us with consent to use your personal information, your consent covers all processing activities carried out for the same purpose or purposes. When the use of your personal information has multiple purposes, PwC Law LLP will seek your consent for each separate purpose for which the personal information will be used.

5. To whom do we provide your Personal Information?

Except for the disclosures described below, we identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. We only disclose Personal Information for purposes related to our provision of services to you, or with your express consent, or if required or authorized by law. For example, we may disclose Personal Information when the disclosure to third parties assists us in providing the legal services that you have requested. We may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — such as service providers that provide telephone support or data storage or processing.

We may also disclose Personal Information when it is necessary to collect outstanding accounts or assess eligibility for credit, or when it is necessary to comply with court orders, regulatory rules (including the rules of applicable provincial law societies) or to satisfy our insurance requirements, or when we reasonably believe that a third party requesting your Personal Information is acting as your agent.

Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of some or all of the business of PwC Law LLP or if we merger or reorganize, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.

PwC Law LLP is a law firm affiliated with PricewaterhouseCoopers LLP (“PwC”) in Canada under the terms of an affiliation agreement filed with the Law Society of Upper Canada. The provision of our advice, legal information and services may necessitate the exchange of information with PwC Canada and members of the global network of PwC and law firms cooperating with members of the global network of PwC. These other jurisdictions may include the United States, India, United Kingdom, Mauritius, Uruguay or the jurisdiction of any other PwC network firm (as per our engagement letters which allow us to draw on the resources of other firms), which latter jurisdiction(s) may be identified upon request. In particular, while electronic data storage for PwC Law LLP is located in Canada and the primary and back-up servers are owned by an affiliated entity of PwC, email correspondence to and from PwC Law LLP goes through PwC (U.S.) servers located in the U.S. Electronic data sent in or as an attachment to an email is simply diverted through such U.S. servers to Canadian located and owned servers and is not permanently stored on U.S. located servers.

To the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

With respect to the PwC Law LLP website, this Privacy Policy applies to the websites located within www.pwc.com/ca/law In addition, there are several places throughout the website that may link to other websites that do not operate under this Privacy Policy. When you link to other websites, PwC Law

LLP’s privacy practices no longer apply to the collection, use and disclosure of Personal Information that you provide on or through them. For this reason, we encourage visitors to review each site’s privacy policy before disclosing any personal information.

6. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing. You may also consent to PwC Law LLP’s collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). PwC Law LLP may also rely on your implied consent to the collection, use and disclosure of your Personal Information where implied consent is permitted under applicable law.

We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

7. How do we ensure the privacy of your

Personal Information when dealing with our affiliates and other third parties?

We ensure that all affiliates and other third parties that are retained to perform services on our behalf and are provided with Personal Information are contractually required to operate in a manner that is consistent with the intent of this Privacy Policy and PwC Law LLP’s privacy and data security policies and practices.

8. How long will we use, disclose or retain your Personal Information?

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

9. How can you access your Personal Information that we have collected, utilized or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes. To submit a written access request, or to obtain further information with respect to your access rights, you may contact our Chief Privacy Officer, as indicated below.

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

We will 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. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

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

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

12. How fast will we respond to your written requests?

We will respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

13. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

We will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. If you do not notify us within such thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.

14. 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 identifying information shall be used only for this purpose.

15. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business ‘need to-know’ or whose duties reasonably require such information.

16. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our Chief Privacy Officer as follows.

Kai Brown

PwC Law LLP

Suite 2500, PwC Tower

18 York Street

Toronto Ontario M5J0B2

E-mail: kai.brown@ca.pwc.com

Telephone: 416-815-5234

© 2015-2018 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.