In keeping with our obligations as legal professionals, we are committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable legislation. Our client relationships are founded on trust and we are committed to maintaining that trust. This privacy policy describes De Sa & Associates Professional Corporation’s (“De Sa & Associates” or “we” or “us” or the “firm”) practices relating to the collection, use and disclosure of personal information provided to us. This privacy policy has been developed in order to comply with the Personal Information Protection and Electronic Documents Act(“PIPEDA”).

This De Sa & Associates 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 DE SA & ASSOCIATES, YOU AGREE THAT WE MAY COLLECT, — USE AND DISCLOSE SUCH PERSONAL INFORMATION 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 the De Sa & Associates 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 De Sa & Associates 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.

What is personal information?

Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. The types of Personal information that De Sa & Associates may collect about you includes your name, home address, telephone number, personal e-mail address, billing and account information, information about a client’s legal issue and other information incidental to providing legal advice and services. Personal Information is to be contrasted with business information such as your name, title or position, business address, telephone number, facsimile number or e-mail address. Business information is not
covered by privacy legislation.

Under the applicable Canadian legislation, the Personal Information Protection and Electronic Documents Act, we follow ten principles when collecting, using or disclosing
your personal information:

1. 1. We are accountable for personal information under our control.
   2. . The purpose for collecting personal information is identified at or before the time it is collected.
   3. We obtain your consent before collecting, using or disclosing your personal information, except where otherwise permitted or required by law.
   4. We limit the personal information we collect to that which is necessary for us to conduct business.
   5. The personal information we collect is only used, disclosed or retained for its original intended purpose (unless you provide your consent to a different use or disclosure) and we retain it only as long as necessary for those purposes.
   6. We take care to ensure that the information we have is accurate,
   7. We safeguard the privacy of your personal information through security measures.
   8. We are open with you about our policies and practices related to managing your personal information.
   9. Upon request, we provide you with access to your personal information, subject to any limitations imposed by law.
   10. We address your concerns. If you have questions or concerns regarding your privacy or this Policy please contact us as described below.

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 province). 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 Insurance 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.
If you establish a solicitor-client relationship with a particular lawyer, you may be required, in the context of that relationship, to provide Sensitive Information for the
purpose of conducting legal services. As noted above, such information is outside the scope of this policy and should never be submitted through this website.
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 below.

Cookies

Our website uses cookies to track your personal preferences when you browse our site. A cookie is a small packet of data sent to your browser from a web server. It is stored on your hard drive and can be recalled to allow easy and quick access to the website upon return. Details such as your contact information, username and password are usually stored in cookies for easy retrieval.

Like many other websites, our Site makes use of “per session” cookie technology. Per session cookies are small text files that contain a unique identification number that is automatically deposited on a visitor’s computer. It is stored on your hard drive and can be recalled to allow easy and quick access to the website upon return. Details such as your contact information, username and password are usually stored in cookies for easy retrieval. These cookies track information during an open session and are stored only temporarily in your computer’s memory. This information helps us determine the total number of visitors to the Site on an ongoing basis and the types of Internet browsers and operating systems (e.g., Windows or Macintosh) that our visitors use. We use this information to facilitate and enhance your online visits. We do not cross-reference this information with any type of personal information that is voluntarily offered through the Site.

The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically. If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser’s cookie options, please refer to the instruction documentation of your particular browser or seek online assistance. You should understand that some features of many sites may not function properly if you don’t accept cookies.

Why do we collect your Personal Information?

In general, De Sa & Associates collects, uses and discloses Personal Information about our clients in order to provide our clients with professional legal services. More specifically, we collect, use and disclose your Personal Information for the following purposesTo establish and manage client relationships, provide legal advice, perform legal services, fulfil legal duties, and avoid conflicts of interest. This may include the sharingof Personal Information by and between De Sa & Associates personnel;

1. To establish and maintain commercial relationships with clients, including to issue invoices, administer accounts, and to collect and process payments;
2. As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
3. For any other purpose to which you consent.

The collection of Personal Information is limited to only that which is necessary for these purposes. We do not use Personal Information to sell to direct marketing agencies
or provide it to anyone outside the firm.

To whom do we disclose your Personal Information?

From time to time, De Sa & Associates may disclose your Personal Information to:

1. Our insurers and to regulatory agencies such as provincial law societies, insurers or others in connection with regulatory or other activities relating to the obligations of De Sa & Associates and its practice of the profession of law;
2. A person who, in the reasonable judgment of De Sa & Associates is providing or seeking the information as your agent; and
3. Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

When Personal Information must be disclosed?

Notwithstanding our commitment to protecting our client’s Personal Information, there are some limited instances where we are obliged to disclose information without consent. These are the following:

1. Where the information is known to the public; and
2. Where required by law or by order of a tribunal.

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

Where do we store your Personal Information?

Your Personal Information is stored in secured locations and on servers controlled by De Sa & Associates located at our offices.

How may you obtain access to your Personal Information?

Upon your written request, subject to certain exceptions, De Sa & Associates will inform you of the existence, use, and disclosure of your Personal Information and will give 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, De Sa & Associates employs administrative and technological safeguards appropriate to the sensitivity of
your Personal Information. A number of measures are taken to ensure the security of our client’s Personal Information. These include the following:

1. Our staff are trained to collect and use Personal Information only as necessary to perform their duties and in accordance with our privacy policy;
2. Our firm restricts the collection of Personal Information to that required for the purposes noted above ;
3. Once Personal Information is no longer required for the purposes noted above and under the rules of the Law Society of Upper Canada, it is destroyed in due course;
4. Paper information is under supervision.

Changes to the Privacy Policy

De Sa & Associates reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will make such revised policy and changes available upon request to the De Sa & Associates Chief Privacy Officer. However, De Sa & Associates 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.

Links

This website contains links to other sites. De Sa & Associates does not assume any responsibility or liability for any communications or materials available at those linked sites. All links are provided for your convenience only; they are not an endorsement or referral by our firm.

Requests for access and challenging compliance

We welcome any requests to verify the accuracy of the Personal Information we have, and the identity of any parties to whom we may have had reason to disclose the information. Should any of our clients wish to make a complaint about our privacy practices, we invite them to notify our Chief Privacy Officer or contact any of our professionals who have assisted in serving them. We will investigate all complaints and provide a timely written response. Should any complaint be found to be justified, we will take appropriate measures to resolve the matter to the satisfaction of the client.

De Sa & Associates has appointed Rafal Kot in our office as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on De Sa & Associates’ privacy practices, please contact the De Sa & Associates Chief Privacy Officer at:

De Sa & Associates P.C.
Chief Privacy Officer
1111 Finch ave w.

Suite 300
Toronto,Ontario
M3J 2E5
Tel: (416) 242-7555
Fax: (416) 242-7333

e-mail: [email protected]

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector. The Information
and Privacy Commissioner can be contacted at:

112 Kent Street
Ottawa, Ontario
K1A 1H3
phone: (613) 995-8210
toll-free: 1-800-282-1376

www.privcom.gc.ca