Privacy Policy

Goldfarb, Shulman, Patel & Co. (GSP) is committed to maintaining the privacy of personal information provided by you, our clients and protecting all personal information in its possession or control. This privacy policy sets out GSP’s practices related to the collection, use, disclosure and protection of your personal information.

Effective January 1, 2004, all businesses engaged in commercial activities must comply with the Canadian government’s Personal Information and Electronic Documents Act (PIPEDA). The obligation to conform to PIPEDA extends to all Canadian businesses including GSP.

Goldfarb, Shulman, Patel & Co. LLP’s privacy policy incorporates the ten internationally recognized standards on which PIPEDA is based.

1) Accountability

GSP is accountable for all personal information in its possession or control. The firm has established and put into effect policies and procedures aimed at properly protecting personal information. The firm has appointed a chief privacy officer (CPO) who is responsible for educating partners and employees regarding our privacy policy and ensuring the firm’s compliance with our privacy policy.

2) Identifying Purposes

GSP collects personal information from you and uses and discloses such information, only to provide the professional services that you have requested. The services provided by GSP are described in an engagement letter with you. The engagement letter includes a description of the personal information the firm will require, why it is required, the uses that will be made of the information and with whom it may be shared in the course of providing GSP’s professional services.

3) Consent

Your knowledge and consent are required for the collection, use or disclosure of personal information. By signing the engagement letter, you provide agreement that proper consents to the collection, use and disclosure of personal information as set out in the letter have been obtained.

4) Limiting Collection

GSP only collects personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means.

5) Limiting Use, Disclosure and Retention

Personal information will only be used and disclosed for the identified purposes, except with your consent or as required by law, including Rules of Professional Conduct. GSP does not disclose personal information to third parties that would enable them to promote their products or services. We may share your personal information with third parties engaged to assist us in providing our services to you or where it is necessary to collect payment for our services.

GSP will retain your personal information for as long as it is necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and regulations.

6) Accuracy

GSP strives to ensure that the personal information we collect is as accurate, complete and up-to-date as is necessary for the purposes for which it is used. You can help us maintain the accuracy and timeliness of your personal information by notifying us of any changes.

7) Safeguards

GSP maintains appropriate physical, organizational, and technological security systems to protect your personal information from loss and unauthorized access. GSP has trained its staff as to the importance of maintaining the confidentiality of personal information.

8) Openness

GSP will make available specific information about its policies and practices relating to personal information.

GSP’s privacy policy is posted on our website. Any questions can be directed to GSP’s Privacy Officer as indicated below:

Privacy Officer Goldfarb, Shulman, Patel & Co. LLP Chartered Accountants 400 Bradwick Drive Suite 100 Concord, ON L4K 5V9

Phone: (905) 326-6800 Fax: (905) 326-5339 E-mail: privacy@gspco.com Website: www.gspco.com

9) Individual Access

Upon request, GSP will provide to you the personal information that is in our possession and to whom we have disclosed this information to. You can amend this information for accuracy and completeness.

10) Challenging Compliance

You will be able to address any concerns regarding GSP’s compliance with the above principles to our Privacy Officer. We will investigate all complaints and take the necessary steps to resolve the issue.

If we are unable to resolve your concerns, you may contact the Privacy Commissioner of Canada. GSP’s Privacy Officer will provide you with this contact information upon request.

About this Document

The Privacy Policy spells out the responsibility of Goldfarb, Shulman Patel & Co. LLP and your rights as a client or other individual regarding the collection, use and disclosure of your personal information.

This Privacy Policy is subject to amendments which will be updated on GSP’s website and will also be available from GSP’s Privacy Officer