Davis Webb LLP Privacy Policy Policy on the Collection, Use and Disclosure of Personal Information

Consistent with our obligations as legal professionals, we are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. This Policy Statement 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 information provided to the Firm.

Our obligations as legal professionals are governed, in part, by the Rules of Professional Conduct that govern each of our lawyers as members of the Law Society of Upper Canada. These obligations apply to all members, 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 members, associates and employees of Davis Webb LLP ("the Firm").

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 the 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 the Firm agrees to be retained to provide services to a particular individual or organization. In order to protect their owns interests, individuals or organizations should not send confidential information to the Firm until they have had a direct discussion with a professional at the Firm regarding the retention of the Firm to provide legal services.

Despite this general rule, there are circumstances where disclosure may be justified or permitted or we are obliged to disclose information without consent. To illustrate, these circumstances could include:

Where the information is known to the public; Where required by law or by order of a tribunal; Where we believe, upon reasonable grounds, that there is an imminent risk to an identifiable person or group of death or serious bodily harm; Where it is alleged that a member, associate or employee of the firm is guilty of a criminal offence; civilly liable in a legal action or guilty of malpractice or misconduct; Where it is necessary to establish or collect fees.

In such circumstances, we will not disclose more information than is required.

We collect only such information from individuals or organizations as is required for the purposes of providing our services to them. We do not sell, trade, barter or exchange any information obtained, including and especially any information obtained in the course of professional relationships.

Davis Webb LLP endeavors to maintain the accuracy of any information in its possession on active matters. Information contained in documents where a file has been closed is not actively updated or maintained.

In the event of any question concerning the management of their information, clients should address such questions to the professional responsible for the matter.

Davis Webb LLP endeavors to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use, or modification.

Visiting our site A visitor to a Davis Webb LLP site is not required to reveal any individually identifiable information, such as name, address, or telephone number. Nor is such information collected passively by electronic means.

Our server tracks general information about visitors such as their domain name and time of visit. The Firm's site also collects and aggregates information regarding which pages are being accessed as well as information volunteered by visitors through online surveys. 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

Following its use, the information collected is not retained but, rather, is discarded in a secure manner.

Any other information provided to us via a Davis Webb LLP site is subject to the general rule described above.

Evolving Practices This statement is in effect as of October, 2012. Davis Webb LLP will from time to time review and revise its privacy practices in conformity with the law and this Policy Statement.

Questions If you have any questions or concerns regarding our privacy practices, please contact a Davis Webb LLP professional. The matter will be directed to the appropriate person within our Firm.