TECHNOLOGY & PRIVACY POLICY

CONSENT

By using our websites, and those of companies used to provide services on behalf of Apex Legal, you consent to the collection, use, storage, transmission and disclosure of your personal information in accordance with this Apex Legal Technology & Privacy POlicy (the "Policy"). In the Policy, You means you, the user, visitor and client ("You" and "Your"), while We and Us means Apex Legal.

Apex Legal recognizes the importance of privacy and the sensitivity of personal information. As lawyers we have a professional obligation to keep confidential all information we receive within a lawyer-client relationship. We are committed to protecting any personal information we hold. This Technology & Privacy Policy outlines how we manage your personal information and safeguard your privacy.

VOLUNTARILY PROVIDED PERSONAL INFORMATION

We use forms so you may voluntarily provide us with your personal information. If you provide us with your personal information, we may use your personal information to provide services and to understand how you use our website and online tools. By completing our forms, you provide us with your consent to use the information in this manner.

We will use the information for the purposes for which you requested. In some cases, we may provide your information to a third party we engage to assist us in the provision of services to you.

EMAIL POLICY

We communicate with you regarding our services, publications and events in various ways, including by email. If you received an email from us, your email address is either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future or you have an existing relationship with us. We respect your time and want to ensure we only send information to you that you will find valuable. We will always permit you to unsubscribe or opt-out of receiving these emails.

EMAIL AND WAIVER OF CONFIDENTIALITY

Email is an inherently vulnerable form of communication. When information is transmitted by email, it is broken into packets of data that flow between servers over the internet. Technologies exist that allow interested parties to spy, sniff and sort through packets of information transmitted by email without your consent.

While Apex Legal will make commercially reasonable efforts to maintain the security and confidentiality of information transmitted by email, you waive your expectation of confidentiality on any and all information transmitted between you, Apex Legal and any person or entity delivering services for or on behalf of Apex Legal.

COOKIES

Apex Legal does not use cookies. The companies and service providers that provide services on behalf of Apex Legal may use cookies, and this use is governed by each service provider's terms of service and privacy policy. Your acceptance of the Policy also constitutes your acceptance of the terms of use and privacy policies of the Apex Legal service providers.

EXTERNAL LINKS

We may have links on our website to other sites and resources that provide information or materials we feel interests you. We are not responsible for the contents or security of those sites or the collection, use and disclosure of your personal information on those sites. We also disclaim any responsibility for the information, or your reliance on the information, contained on web pages and sites accessible through external links.

LOCATION AND TRANSMISSION OF DATA

You consent to your personal information and any related data collected by Apex Legal and any person or entity delivering services on behalf of Apex Legal being stored, duplicated or located on servers located outside of Canada. You also consent to your personal information and any related data being transmitted outside of Canada, even when transmitted between destinations located within Canada. Personal information and data located or transmitted outside of Canada will be subject to the laws of other jurisdictions.

CONSENT AND OPTING OUT

If you provide us with your personal information for the purposes of receiving emails, opening a file or receiving legal services, you have "opted-in" to our communications and accepted the terms of this Policy.

If we send you an announcement, invitation, message or service related email and you do not "opt-out" of receiving emails or the specific type of communication, including commercial electronic message, you are deemed to have accepted and consented to this Policy. You may opt-out of receiving commercial electronic messages by using the unsubscribe mechanism included in the email.

If you are a client or prospective client of Apex Legal, you may opt out of and decline your acceptance of this Policy by delivering written notice of your intent to opt-out and decline the Policy to Apex Legal. If you opt-out and decline your acceptance of this Policy, Apex Legal may, at its sole discretion, end any client and solicitor relationship that may exist between You and Apex Legal or change the fee or quote to reflect the additional costs incurred by Apex Legal in delivering services using alternate terms, policies or service providers.

YOUR PRIVACY RIGHTS

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, <<http://laws-lois.justice.gc.ca/eng/acts/P-8.6/index.html>> and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. These obligations extend to lawyers and law firms, including Apex Legal. The Act gives you rights concerning the privacy of your personal information.

Apex Legal is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our lawyers and support staff about our policies and practices.

FREQUENTLY ASKED QUESTIONS

What personal information do we collect?

Personal information is any information that identifies you, or by which your identity could be deduced. If we did not collect and use your personal information, we could not provide you with legal services.

How do we collect your personal information?

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, both at the start of a retainer and in the course of our representation.

Sometimes we may obtain information about you from other sources, for example:

• your insurance company;

• your real estate agent in a property transaction;

• from a government agency or registry;

• your employer, if we are acting for you, at its request;

• your accountant.

Use of Your Information

We use your personal information to provide legal advice and services to you, to administer our client (time and billing databases) and to include you in any direct marketing activities. If you tell us that you no longer wish to receive information about our services, or about new developments in the law, we will not send any further material.

Apex Legal does not disclose your personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to other law firms.

Disclosure of your Personal Information

Under certain circumstances, Apex Legal will disclose your personal information:

• when we are required or 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 requires us give your information to third parties (for example 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 at your request, and on your behalf;

• if the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act.

Updating Your Information

Since we use your personal information to provide legal services to you, it is important that the information be accurate and up-to-date.

If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?

Apex Legal takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;

• restricted file access to personal information;

• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;

• internal password and security policies.

Access to Your Personal Information

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

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

Correcting Errors

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

Can I be denied access to my Personal Information?

Your rights to access your personal information are not absolute. We may deny access when:

• it is required or authorized by law (for example, when a record containing personal information about you is protected by solicitor-client privilege);

• to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;

• to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or

• the information was generated in the course of a formal dispute resolution process.

If we deny your request for access to, or refuse a request to correct information, we shall explain why. Apex Legal does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon you.

Can I request anonymity?

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website). The <Proceeds of Crime (Money Laundering) and Terrorist Financing Act> requires us to confirm the identity of all new clients. It may also require us to disclose information to FINTRAC in relation to certain large cash transactions.

CHANGES TO THIS POLICY

Since Apex Legal regularly reviews all of its policies and procedures, we may change our Technology & Privacy Policy from time to time.

REQUESTS FOR ACCESS

If you have any questions, or wish to access your personal information, please write to our Privacy Contact at 207-7800 Woodbine Avenue, Markham, ON L3R 2N7.

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at

112 Kent Street,

Ottawa Ontario, K1A 1H3

1.800.282.1376.

WEBSITE STATISTICS

When you visit our websites, and those of companies that provide services on behalf of Apex Legal (the "Websites"), Apex Legal and our service providers may collect your IP address. We may record what pages you visit and for how long, how you arrived at our site, where approximately you are located (according to IP addresses), what kind of operating system you are on, if you are using a cell phone or tablet to access the site, and what types of media you view on our site.

We may collect anonymous statistics about how visitors use our website to better tailor the knowledge information we provide to meet our visitors' needs. We may use this information to manage our website, develop valuable knowledge publications, seminars and events and to ensure we are keeping our technology upgraded to sufficiently meet your needs.