At Breckenhill, we are committed to protecting your privacy and safeguarding your personal, business and financial information. We support a general policy of openness about how we collect, use, disclose and protect your personal information. The purpose of this Privacy Policy is to inform you of Breckenhill's practices relating to our collection, use, disclosure and protection of your personal information. By purchasing our professional services and products, you consent to our collection, use, disclosure and protection of your personal information in accordance with specific terms and conditions. The specific terms and conditions are listed below.

This Privacy Policy is designed to meet the compliance standards established by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA is based on the Ten Principles established by the Canadian Standards Association's Model Code for the Protection of Personal Information, which principles were recognized as a Canadian standard in 1996, and address the ways in which organizations should collect, use and disclose personal information. We also note that in addition to these standards, we continue to be subject to the confidentiality rules, concerning client information, of the Institutes of Chartered Accountants.

Our Privacy Policy explains how you can contact us if you have a question about, want to make a change to, or delete, any personal information that Breckenhill may retain about you. For purposes of describing the firm and its legal entities in this policy, Breckenhill refers to Breckenhill Inc.

Definition of personal information

"Personal information" means any information about an identifiable individual, other than that individual's name, title, business address or telephone number (often called, "business card" or "phone book" information). Personal information includes age, gender, marital status, health status, financial status, home address, etc. Such information includes information specifically related to you, our client, or personal information of others, such as your employees, clients, or customers, that we may encounter in the course of providing our professional services to you.

What personal information do we collect?

The information we collect, which may include personal information, may involve at least some of the following:

Contact information (such as name, nicknames, titles, business names, business addresses, email work addresses, work or cell telephone numbers); and Financial status and billing information (such as credit card numbers/expiration dates and credit history).

How do we use your personal information?

We use your personal information to:

• Provide you with timely and reliable professional assurance, tax or advisory services;
• Do all the things necessary to administer those services;
• Research, develop, manage, protect and improve those services;
• Develop and maintain our relationship with you and communicate with you;
• Advise you about new firm products and services that may be of interest to you; and
• Invoice and collect payment for professional services and products provided by us to you.

When do we disclose your personal information?

At Breckenhill, we are accountable for your personal information. We will not sell, license, trade or rent your personal information to, or with, others. In terms of our accountability to you:

• We are responsible for the protection of the personal information you disclose to Breckenhill;
• We have appointed a Chief Privacy Officer, Mr. William Wilson, Managing Partner, Breckenhill Inc., to be accountable for our compliance with our Privacy Policy;
• With your consent, we may share your personal information with third parties engaged to assist us in providing the products and services to you. These service providers will sign Breckenhill Confidentiality Agreements and will be prohibited from using your personal information for any purpose other than to provide a specified service to you as a client of Breckenhill. They will be required to protect the personal information disclosed by Breckenhill as we ourselves would do, and to comply with the general privacy principles described in this Privacy Policy;
• We reserve the right to disclose personal information to a third party if a law, regulation, regulatory body, search warrant, subpoena or court order legally requires or authorizes us to do so; and
• We also reserve the right to disclose and/or transfer personal information to a third party in the event of an actual merger or acquisition of Breckenhill so that you may continue to receive the same professional services from the new entity or third party. In this unlikely case, the use of your personal information by the new entity would be limited to the purpose(s) for which we originally used the information.

Your knowledge and consent

Breckenhill collects personal information about you only when you voluntarily provide it. Typically, we will seek your consent for the use or disclosure of your personal information when we collect it. In certain circumstances, your consent may be sought after the information has been collected but before we use it (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Should you wish to do so, please contact our Chief Privacy Officer, William Wilson, in writing, at our Breckenhill Canada Privacy Office. The firm will inform you of the implications of your withdrawing your consent.

We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

Use or disclosure of personal information for marketing

Breckenhill will never disclose your personal information to a third party marketing firm. However, within the boundaries of our regulatory environment, from time to time Breckenhill may make use of your personal information, with great discretion, to communicate and market our services and products to you. You can choose not to receive any invitations or direct mail from us by indicating your preference as outlined below under Contact Us.

Cookies

When you visit our Web site (www.breckenhill.com) please note that cookies may be used on some pages of our site. "Cookies" are small text files placed on your hard drive that assists us in providing a more customized Web site experience. For example, a cookie can be used to store registration information in an area of the Web site so that a user does not need to re-enter it on subsequent visits to that area. It is Breckenhill's Internet Privacy Policy to use cookies to make navigation of our Web sites easier for our visitors and to facilitate efficient registration procedures.

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our Web sites.

In order to properly manage our Web site, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our Web site presents the best web experience for visitors and is an effective information resource.

Links to third-party websites

There are several places throughout www.breckenhill.com that may link to other Web sites that do not operate under Breckenhill's Internet Privacy Policy. When you link to other Web sites, Breckenhill's Web and privacy policies no longer apply. We encourage you to review each site's Privacy Policy before you disclose any personally identifiable information.

How we protect your personal information

Breckenhill will take all commercially reasonable steps to ensure that your personal information in our possession, collected from you, is protected against loss and unauthorized access. This protection applies to information stored in both electronic and hard copy form. Access to your personal information will be restricted to selected employees or representatives. In addition, Breckenhill will employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access.

Retention of your personal information

Breckenhill will retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and regulations. Your consent to such purposes(s) will remain valid after termination of our relationship with you.

Exceptions, qualifications and changes to this policy

Although not listed in detail in this Privacy Policy, the firm will rely on any exceptions or qualifications that are set out in the applicable legislation as permitted by law.

Breckenhill reserves the right to modify this Privacy Policy at anytime without notice. The Privacy Policy posted at anytime or from time to time via the Breckenhill Canada Web site (www.breckenhill.com) shall be deemed to be the Privacy Policy then in effect.

Correcting or updating your information

You can help us maintain the accuracy of your personal information by notifying us of any changes to your information. To correct or update your personal information, you may contact Breckenhill by email as indicated on the left.