PRIVACY POLICY

Introduction

ClearBlue Markets Inc. ("ClearBlue" or "we") is committed to protecting the personal information that we collect, use and disclose in the course of providing services and operating our business, in accordance with all applicable regulatory requirements, including applicable privacy legislation, and consistent with our professional obligations. This Privacy Policy sets out in general terms how we collect, use, disclose and protect the personal information of our clients, other individuals and our website users ("you").

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"Personal Information"

Privacy legislation in Canada defines "personal information" broadly as any information about an identifiable individual. In general, personal information does not include business contact information, including your name, title or position, business, telephone or facsimile number.

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Accountability

Under applicable privacy legislation, ClearBlue is responsible for the personal information in our possession or control. This includes personal information we receive directly, such as from individual clients or other individuals, and personal information we receive indirectly from clients or others. We have established policies and procedures with the objective of protecting personal information and have appointed a Privacy Officer to oversee privacy matters for our company. Our Privacy Officer can be reached at questions@clearbluemarkets.com.

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What Personal Information Do We Collect?

The types of personal information we may collect about you include your name and home contact information, billing and account information, and other information incidental to the provision of advice and services by our company. Examples of the types of personal information we may collect include personal information about directors, officers and employees of a client or other party, witnesses, beneficiaries, family members, adverse parties or parties-in-interest, and information about shareholders, security-holders, investors, potential investors or buyers, business partners, targets, competitors or customers of clients, individuals, clients, pension plan members, or other parties who are individuals.

We may also collect information about your online interactions through our osler.com website and our other web-enabled extranet services (collectively, the “Sites”), our email communications, and our online ads. We may collect this information for the purposes of (i) tailoring content that we may send or show you, (ii) to authenticate you, enable access to information, and otherwise administer the Sites, and (iii) for analytical purposes to better understand digital interactions with our firm.

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Sites

• Cookies - Cookies are small elements of data placed on your devices when you visit a website in order to track use of the site and to improve your user experience. We may, from time to time, collect personal information about you and your use of the site through the use of cookies as outlined above. Some browsers can be set to reject all cookies; if you choose to modify your browser in this manner, not all features offered through our Sites may remain available.

• Online Communications - In order to provide our Site users with publications, information or requested services, visitors may voluntarily submit personal information to us for such purposes as subscribing to or downloading publications, participating in a seminar or other event, participating in surveys or asking a question. We use the personal information you provide only for the purpose for which you have provided it. If a subscriber or visitor has subscribed or attended a seminar or other event in the past, we may combine the information with information submitted on the Sites. We provide an ongoing opportunity to unsubscribe or opt out of contact with the firm in the footer of each e-mail or by e-mail request to questions@clearbluemarkets.com.

• E-Mail Communications - We may send e-mail communications to subscribers or other individuals in our contact database to advise them of legal developments, distribute publications, or advise them of events or seminars. Each e-mail includes an opt-out feature and instructions on how to un-subscribe if you do not wish to receive future e-mails from ClearBlue for these purposes.

• Links - Our Sites may present links to other websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. ClearBlue is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies before providing them with your personal information.

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Service Providers

To the extent we enter into arrangements with service providers, agents and contractors to store, handle or process personal information on our behalf, such as for data processing, document storage software support and office services, our policy will be to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

 

Internet Advertising

We may also use third parties to serve advertisements on our Sites and on third-party websites. These companies may use cookies, tracer tags or web beacons to report information about your interaction with our email communications, Sites and online ads for the purposes of tailoring content that we may send or show you and for analytical purposes to better understand digital interactions with our brand. To learn more or to opt out of tailored advertising, please visit http://youradchoices.ca/choices

 

Limited Collection, Use and Disclosure

We collect personal information by fair and lawful means and, wherever appropriate, directly from the individual. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate to provide our legal services, advice and representation and to operate our firm business. We limit the personal information we collect and use for client relationship and development purposes and for our publication and seminar programs to contact information and information about preferences provided by the individual.

We keep records of the work performed and services provided by us in accordance with applicable regulatory requirements and professional standards. These records may include personal information. Our records are stored with safeguards against inappropriate or unauthorized access.

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Challenging Compliance with this Privacy Policy

ClearBlue will respond to complaints from individuals or questions about our compliance with this policy and with applicable privacy laws. We will investigate and attempt to resolve all complaints.

If you have any questions or concerns about this privacy policy or our treatment of personal information, please contact our Privacy Officer at the coordinates listed above.

We may change our Privacy Policy at any time by posting a new Privacy Policy on our Sites.