CUNNINGHAM LLP CHARTERED ACCOUNTANTS

PRIVACY POLICY

Protecting our client’s confidentiality and privacy is nothing new to Cunningham. Our reputation has always rested on this commitment. As Chartered Accountants in Ontario, we are governed by The Institute of Chartered Accountants of Ontario (“ICAO”). The ICAO rules and regulations have always required the highest standards in regard to client confidentiality and privacy. In order to ensure compliance with the above standards, we will only collect personal and corporate information necessary to provide the following services to our clients:

1. For the preparation of any necessary income tax returns required to comply with the various Federal, Provincial and other regulatory Acts.
2. For the preparation of financial statements and related services.
3. To assist in providing consulting services included but not limited to personal and corporate income tax planning, estate planning, Research & Development services, valuation services and other business and personal advisory services.
4. To be used for mailing newsletters and other written materials for the educational benefit of our clients.

CONSENT

Cunningham takes steps to ensure that its clients know and understand the purposes for which Cunningham collects uses or discloses personal and/or corporate information. Cunningham will obtain its clients consent to collect, use or disclose personal and/or corporate information. Depending on the circumstances and the nature of the information, consent may be express or implied. Consent as discussed below can be withdrawn at any time.

1. We will not collect, use or disclose your personal information without your consent. By providing us with your information for the purposes described above, you consent to our collection and use of the information for those services, which also includes the transmittal of this information to the various Federal, Provincial and regulatory agencies that may request this information for taxation and other regulatory purposes.
2. You have the right to withdraw consent for any use of the collected information. However, withdrawal of consent may in some cases effect the ability of Cunningham to provide many of our services. Should our ability to provide the necessary services be compromised by the withdrawal of your consent, we will advise you accordingly.
3. Cunningham will inform its clients by means of correspondence and/or its internet website of any changes to its Privacy Policy.

Accuracy of Personal Information

Cunningham will take steps to ensure that the personal/corporate information it holds regarding clients is up-to-date and complete where required for the purposes for which it was intended. Information in respect of former clients will be retained and safeguarded as long as we deem it necessary to meet regulatory and income tax requirements.

1. Cunningham updates personal information regarding clients based on information communicated to it by its clients.
2. Cunningham requests that clients ensure that the information they provide Cunningham is up-to-date and accurate and that where possible they inform Cunningham of changes to such information.

Measures for Security of Information

Cunningham will protect it client’s personal and corporate information by means of physical, technological and administrative security measures.

1. The security measures put in place by Cunningham are intended to protect personal and corporate information against loss or theft and against unauthorized disclosure.
2. Information disclosed to Cunningham during the preparation of financial statements or income tax returns regarding our clients employees, customers, suppliers and other third parties will be kept private and confidential and not released to any third party without our clients consent.
3. Where Cunningham deems the destruction of personal/corporate information necessary, we will ensure secure destruction and disposal of this information.

Employees

Most of our professional employees are subject to the rules and regulations of the ICAO. Both these employees and our non-professional staff have been made aware of their responsibilities in regard to privacy and confidentiality of client information. All employees must enter into employment contracts with Cunningham. These contracts all contain a client confidentially clause.

Questions and Complaints

Any questions or complaints may be directed to our Chief Privacy Officer, Mark Goodfield at mark@cunninghamca.com or by calling 416-496-1051.