At Harris + Harris LLP (“H+H”, “we” or “us”), we respect the privacy rights of individuals and we are committed to keeping personal information accurate, confidential, and secure. We have adopted the following Privacy Policy to ensure that we continue to meet our commitment to privacy. Please review our Privacy Policy carefully to understand how we collect, use, protect and handle your personal information.

H+H is a full-service business law firm in Toronto. The lawyers and staff at H+H are committed to protecting your privacy.

Since January 1, 2004, all organizations collecting, using or disclosing personal information in Canada in the course of commercial activities have been required to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any applicable “substantially similar” provincial legislation. These obligations extend to lawyers and law firms, including H+H.

In addition, as a professional services firm, we have professional and ethical obligations to keep confidential the information we receive in the context of a lawyer-client and agent-client relationship.

H+H is committed to the proper management of the personal information of clients and others, and of all visitors to our website (the “Site”) that we collect, use and disclose in the course of business.

Personal information is defined in PIPEDA as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card (other than an e-mail address which is considered to be personal information).

In providing legal advice to clients, we have a professional obligation to maintain the confidentiality of information that we receive within a lawyer–client relationship. The practices set out in this privacy policy (the “Policy”) seek to balance the individual's right to the privacy of his or her personal information and H+H’s need to collect, use or disclose personal information for legitimate business purposes in Canada. Controlling the collection, use and disclosure of personal information is an ongoing process. We will continue to review our personal information management practices and improve them as necessary to better protect the privacy of individuals.

Personal information means any information about you or that can be used to identify you as an individual, including information in your résumé or about your employment, the matter about which you retained or contacted H+H, your account with us and any other information that you choose to provide to H+H.

We follow 10 principles when collecting, using and disclosing your personal information:

By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.

We will not, as a condition of supplying a service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the services requested. The form of the consent that we will seek before collecting, using or disclosing personal information may vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent and opt-out consent. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given.

You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its purpose to H+H. H+H will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude H+H from providing legal or other services. If you provide us with the personal information of another individual, you represent and warrant that you have the authority to do so, including where applicable that you have obtained the necessary consent of the other person for us to collect, use and/or disclose their personal information.

We will not collect personal information indiscriminately. We will limit the amount and the type of information we collect to that necessary to fulfill the purposes we have identified to you, or as otherwise permitted or required by law. We may also collect information about your business and business interests or your personal interests to better serve you and foster our relationship. We collect and use personal information:

When possible, we will collect personal information from you directly. However, to provide legal services to clients or for legal, administrative, marketing or management purposes, we may also collect personal information through outside sources such as credit bureaus, government agencies or institutions, employment and other references, employers and service providers.

Certain information may be collected on the Site through various technologies, described below, without your actively providing the information.

Our website is hosted on servers shared with an Internet Service Provider (“ISP”). Any personal information collected on our behalf by the ISP, such as server log data (see below), is managed in accordance with this Policy and is protected by applicable law.

Certain information about Internet users’ traffic patterns is passively and automatically collected and linked to users’ Internet Protocol (“IP”) addresses. These unique IP addresses are assigned to all Web users by their ISPs, and are automatically logged by Internet servers. While the IP address itself does not identify an individual, it may, in appropriate circumstances such as an investigation of a security breach, be used with the cooperation of the ISP to locate and identify an individual using the website.

In the normal course of establishing and maintaining Internet connections, our servers automatically log information about visits to our website. Server logs record statistical information, such as a visitor’s IP address and type of operating system, the time and duration of visit and Web pages requested. The server logs also identify categories of visitors by items such as domain and browser type. These statistics are reported in aggregate form to us and are used to improve our website and ensure that it provides the optimal online experience for visitors.

We do not link server log information to any other data in a way that would enable us to identify individual visitors, except for security purposes, as discussed above.

We may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit our website. This information is collected using “cookies” and might include the pages you visited, your IP (Internet Protocol) address and other site usage statistics. This anonymous information is used for research and analytical purposes only (like evaluating how many visitors our website receives or which pages are visited most often). It does not reveal any personal information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information. “Cookies” are small text files that contain a unique identification number that allows our computers to identify your web browser (but not you) each time you visit our website. The information helps us improve the functionality of the site and enhance the navigation and security of your session. Most major websites use this technology and most browsers are set up to accept them.

The Site also uses third party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. This means we will show ads to you across the Internet, specifically on the Google Display Network. We do not collect personal information through the use of Google's or any other third-party remarketing system. Rather, the third-party vendors will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to continue to market our services to those who have shown interest in our firm.

You may opt out of Google's use of cookies by visiting Google's Ads Settings. Also, you can opt out of other third party vendors' use of remarketing cookies by visiting the Network Advertising Initiative opt-out page.

We use personal information only as described in this Policy or as otherwise disclosed to you or permitted or required by law. Before your personal information is used or disclosed for a new purpose, we will ask for your consent unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law.

H+H generally uses personal information about clients for the provision of legal advice, including obtaining and carrying out client instructions, reporting and communicating with clients, billing and accounting, and protecting against fraud, illegal activities or error. H+H may also use your personal information to maintain our knowledge management system, to manage our business, and to engage in business transactions involving H+H. We may also use personal information to send you newsletters about our services or about legal developments that we think would interest you and to invite you to client functions, seminars and sporting or cultural events.

We may distribute practice group bulletins, articles and other legal updates and publications to people on our mailing lists, who can elect to receive materials on one or more subject matters. We typically distribute such materials by e-mail and other forms of commercial electronic messages. At any time, you may change your preferences or unsubscribe from our mailing lists.

If you send personal information through our Site, we will use it to assess website use and traffic, and to respond to your feedback, questions and comments.

We disclose personal information only as described in this Policy, with your consent, or as otherwise permitted or required by law. To provide legal services, we may sometimes disclose our clients’ personal information to H+H affiliates and to third parties, including foreign agents and government or regulatory agencies.

We may disclose personal information:

Your personal information may be processed, accessed and/or stored in Canada or another jurisdiction, and will be subject to the laws of that jurisdiction.

H+H will retain information, including personal information, for as long as it is needed for the purposes for which it was collected. For example, if you send us personal information electronically to apply for employment with H+H, we will retain your personal information for a reasonable period to permit future consideration for employment. H+H may also be subject to legislative requirements regarding the retention of certain types of information.

We use the standard safeguards of the legal profession to protect the security of personal information in our possession, including physical, organizational and technological measures.

We will use reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, use and disclosure. We have controls in place to maintain the security of our information and information systems. Files containing personal information are stored according to the sensitivity of the information contained therein and are backed up at offsite locations. Appropriate technological controls (such as passwords, encryption, firewalls) are placed on our computer systems and data processing procedures. Physical controls (such as locked filing cabinets, restricting access to offices, alarm systems) are in place as are organizational controls (such as staff training and access on a “need to know basis”).

We may store and process your personal information at our offices in Canada, or elsewhere, including outside Canada. To the extent we employ third-party service providers to store, access, handle or process personal information on our behalf; we will use contractual and other means in an attempt to provide a comparable level of protection. Service providers, however, may be located in various countries, so please be aware that authorized officials of governments in those countries may be lawfully able to access your personal information without your knowledge or consent pursuant to the laws of such countries.

You can ask to view your personal information by writing to the Privacy Officer, whose address and link are provided at the end of this Policy. You can request that corrections be made where you can show that the information we possess is inaccurate. Please note that under certain circumstances, you may not be permitted access; for example, where the disclosure of your records would cause security, legal or confidentiality concerns.

The Site may contain links to other websites. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the content or privacy practices of other websites. We strongly encourage all Site visitors to review the privacy statements and policies of all external websites.

By using our website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use our website. We do not knowingly collect information from or about persons younger than thirteen years of age and if we became aware of such collection, such information will be deleted.

We may amend this Policy at any time. We will post the Policy as amended on our website and will take reasonable steps to inform you of any amendments.

More Information About H+H's Privacy Practices

Please contact the lawyer with whom you are dealing with any questions or concerns you have about this Policy or H+H’s handling of your personal information, or contact our Privacy Officer:

Derek D. Yu

295 The West Mall, 6th Floor

Toronto, Ontario M9C 4Z4

Tel: 416-798-2722 x.269

Email: derekyu@harrisandharris.com