Privacy Policy

At GIBBS & ASSOCIATES, we are committed to maintaining the accuracy, security and privacy of Personal Information in accordance with applicable legislation. This GIBBS & 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").

BY SUBMITTING PERSONAL INFORMATION TO GIBBS & ASSOCIATES OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN 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 GIBBS & 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 the legal services or information which may be of value to you.

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. Generally speaking Personal Information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or e-mail address. The types of Personal Information that GIBBS & ASSOCIATES may collect about you includes your name, home address, telephone number, personal email address, billing and account information, information about a client's legal issue and other information incidental to providing legal advice and services (including Personal Information about witnesses, family members, beneficiaries, directors, officers, employees, adverse parties, parties-in-interest, investigators, decision makers, experts, other professional advisors, and our clients' business partners, investors, shareholders, competitors and customers whom are individuals).

In general, GIBBS & ASSOCIATES collects, uses and discloses Personal Information about our clients and service providers in order to provide our clients with professional legal services. More specifically, we collect, use and disclose your Personal Information for the following purposes:

• provide legal services to you, in accordance with your instructions;
• bill you for legal services rendered;
• provide information to you about developments in the law; and
• advise you of upcoming firm events.
• for any other purpose to which you consent.

From time to time, GIBBS & ASSOCIATES may disclose your Personal Information:

• when we are required our authorized by law to do so, for example if a court issues a subpoena;
• when you have consented to the disclosure;
• when the legal services we are providing to you require us to give your information to a third party (for example, to a lender in a real estate mortgage transaction) your consent will be implied, unless you tell us otherwise;
• where it is necessary to establish or collect fees;
• if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy;
• if we engage expert witnesses on your behalf;
• if we retain other law firms in other jurisdictions, on your behalf; or
• if the information is already publicly known.

Your Personal Information is stored in secured locations and on servers controlled by GIBBS & ASSOCIATES, located either at our offices or at the offices of our service providers.

You may ask for access to any personal information we hold about you.

Summary information is available on request. More detailed requests that require archival or other retrieval costs may be subject to our normal professional and disbursement fees.

We may deny access when:

• denial of access is required or authorized by law (for example, when a record containing personal information about you is subject to a claim of legal professional privilege by one of our clients);
• information relates to existing or anticipated legal proceedings against you;
• when granting you access would have an unreasonable impact on other people's privacy;
• when to do so would prejudice negotiations with you;
• to protect our firm's rights and property;
• where the request is frivolous or vexatious.

If GIBBS & ASSOCIATES holds information about you, and if you can establish that it is not accurate, complete and up-to-date, GIBBS & ASSOCIATES will take reasonable steps to correct it.

Cookies - When an individual visitor accesses the GIBBS & ASSOCIATES Website, we may use a browser feature called a 'cookie' to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the Website from which the visitor came, date and duration of the visit, number of visits, average time spent on our Website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor's browser, but not necessarily the visitor, to our computers each time our Website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the Website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this Website information and share it with other organizations with whom we have a commercial relationship to measure the use of our Website, to improve the functionality and content of the Website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our Website.

E-Mail Communications - Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of GIBBS & ASSOCIATES and other third parties with whom we have a relationship. You may contact us any time if you decide you do not want to receive any future marketing or promotional e-mails from GIBBS & ASSOCIATES.

Links - Our Website may contain links to other Websites which are provided as a convenience only. Visitors are advised that other third party Websites may have different privacy policies and practices than GIBBS & ASSOCIATES, and GIBBS & ASSOCIATES has no responsibility for such third party Websites.

Changes to the Privacy Policy

GIBBS & 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 post such changes on our Website and make such revised policy and changes available upon request to the GIBBS & ASSOCIATES Chief Privacy Officer. However, GIBBS & 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.

Further Information

GIBBS & ASSOCIATES has appointed Michelle Gibbs (née Brodey) as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on GIBBS & ASSOCIATES' privacy practices, please contact the GIBBS & ASSOCIATES Chief Privacy Officer at:

GIBBS & ASSOCIATES
Chief Privacy Officer
150 York Street, Suite 1810
Toronto ON M5H 3S5
Tel: 416-361-0024
Fax: 416-361-1992