Privacy Policy

Contents

1. Purpose of the Policy

2. Nature and Collection of Personal Information

3. Use of Personal Information

4. Data Transfer and Storage

5. Security

6. Disclosure of Personal Information

7. Retention and Deletion of Personal Information

8. Rights Relating to Personal Information

9. Policy Amendments

10. Contact

Privacy Policy (the "Policy")

Me Alice Raynard and Raynard Consult (collectively, "the firm") are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information in their possession. This Policy describes how the firm collects, uses, discloses, and protects the personal information of individuals who do business with the firm or work for the firm. The firm is committed to protecting and respecting the privacy rights of its clients. This Privacy Policy describes how the firm collects, uses, discloses, and protects the personal information collected by the firm.

1. Purpose of the Policy

The purpose of this Policy is to inform clients, partners, and website visitors of the firm’s practices regarding the collection, use, disclosure, and protection of personal information.

2. Nature and Collection of Personal Information

The firm collects personal information when an individual provides it directly—for example, when contacting the firm for legal or consulting services, registering for firm events, or browsing the firm’s website or a site used in the context of a client mandate (e.g., a data-sharing site).

This personal information may include first and last names, address, email address, telephone number, and any other personal information relevant to the firm's services and the fulfillment of mandates, such as:

· Employment Information:Job title and employer name;

· Identification Information:Copies of driver's licenses, passport data, and sources of funding;

· Financial and Billing Information:Bank account and billing address;

· Information related to a legal issue:Opinions, finances, assets, employment, family, taxes, and insurance;

· Personal information about a client, supplier, consultant, or subcontractor, as well as their directors, officers, shareholders, guarantors, employees, or opposing parties, actual or potential witnesses, other lawyers, mediators, and arbitrators;

· Marketing Information:Preferred communication method and area of law, registration for newsletters or seminars, feedback, and survey responses.

The firm does not use profiling tools. Should this change, this Policy will be updated.

If an individual provides the firm with personal information about other individuals, this individual represents that they have the authority to do so and have obtained the necessary consent from the other concerned individuals.

3. Use of Personal Information

The firm uses personal information to:

· Verify conflicts of interest or decide whether to enter into a professional relationship with a supplier or another third party;

· Honor its legal and professional obligations (codes of ethics, client identity verification, anti-money laundering requirements);

· Communicate with clients, suppliers, and third parties, and manage client files;

· Provide legal advice or act on behalf of a client;

· Use precedents;

· Manage billing and accounting;

· Distribute newsletters and seminars (subject to consent, which may be withdrawn at any time);

· Communicate with a client and sending them greeting cards or other greetings;

· Conduct internal, external, and regulatory audits;

· To ensure personal safety and emergency preparedness (in the case of information regarding on-site visitors and guests);

· Any other reason permitted or required by applicable laws or to which the client has consented.

The firm shares personal information with third parties only when necessary for the performance of the services to be rendered by the firm, and always in compliance with applicable laws. The personal information thus collected is accessible only to the firm.

4. Data Transfer and Storage

The firm’s servers are located in Canada, but the firm may use commercial software and services hosted elsewhere to store or process certain data. When data is stored outside of Canada, it may be accessed by foreign law enforcement, governments, or courts.

5. Security

The firm employs appropriate physical, electronic, and procedural measures to protect its systems and personal information against unauthorized access. Security measures are adapted to the sensitivity of the information collected.

The firm disclaims all liability for harm resulting from the misuse of confidential information during any exchange. The firm prioritizes email communication and, unless otherwise instructed in writing, may use unencrypted text.

6. Disclosure of Personal Information

In the course of providing its services, the firm may be required to disclose collected personal information to third parties, other service providers, or agents acting on its behalf. The firm discloses information to a third party when the individual has consented to the disclosure to that specific third party for a determined purpose; when the third party acts on behalf of the firm as an agent or service provider (for example, IT service providers, hosting providers, or marketing solution providers), solely for the purpose of providing those services; or when applicable laws require or permit it.

For example, personal information may be disclosed to other professional services firms (in connection with the firm’s legal services) and to support service providers (storage, technology, finance, accounting, human resources, marketing, insurance, communications, software, and any other service that supports or relates to the practice of law). These third parties may store or process personal information for the firm in Canada or elsewhere (data storage and processing, cloud computing, application hosting, administrative services, etc.).

When the firm discloses personal information to third parties (for example, to an archiving service provider) or to third-party services related to the services offered to clients, it enters into agreements with these third parties stipulating the authorized uses and including a commitment from the third parties to provide a level of protection for personal information comparable to that of the firm. Residents of Québec should note that their personal information may be communicated outside of Québec or Canada for the purposes previously described, such as collection, use, disclosure, or retention. The firm does not sell, rent, or exchange client lists or any other personal information.

However, certain circumstances may require the firm to provide personal information to third parties for legal or regulatory purposes.

Lawyers are required to protect the personal information of clients in consideration of their professional responsibility. The rules governing solicitor-client privilege also protect this information, which a lawyer must never disclose without having previously obtained instructions from the client. Current legislation regarding the protection of personal information in no way undermines solicitor-client privilege, but rather specifies that no provision of the law affects it. Consequently, the firm will protect all personal information covered by solicitor-client privilege.

Upon request by a client, the firm has a professional obligation to indicate what personal information is contained in their file.

7. Retention and Deletion of Personal Information

The retention period for personal information depends on the services provided and the nature of the personal information. The firm’s Policy on record retention requires that client files be kept for the periods set by the competent law societies. These prescribed periods last between seven (7) and fifteen (15) years (depending on the jurisdiction) after the file closure date. Furthermore, the Policy may provide for a longer retention period for certain types of files due to their nature. When personal information is no longer required by the firm or by law, the firm deletes or destroys it in accordance with its current policies and procedures.

8. Rights Relating to Personal Information

Every person has the right to access their personal information, to rectify it, to withdraw their consent to its use, or to request its deletion within the framework provided by current legislation. To exercise these rights, please contact our Privacy Officer at alice@raynardconsult.ca.

Any person may contact the firm’s Privacy Officer to obtain further information regarding the Policy and related procedures, to request access to certain personal information the firm may hold about them, or for any questions or concerns. The firm reserves the right to request personal information from any person to verify their identity. The firm may also charge reasonable fees for processing access to information requests. Where applicable, the firm will provide a prior estimate and may request payment of part or all of the fees as a deposit.

Any person who believes that the firm is not fulfilling its responsibilities regarding the protection of personal information may file a complaint with the Privacy Officer. The firm will respond promptly and make every effort to address the issues raised. The firm may then contact the complainant to obtain additional information necessary for its investigation and to communicate its findings. If the investigation concludes that the complaint is well-founded, the firm will take appropriate measures to rectify the situation.

It is also possible to file a complaint or ask questions to the Office of the Privacy Commissioner of Canada (1-800-282-1376 or info@privcom.gc.ca) or, for Quebec, in writing to the Commission d’accès à l’information – Direction de la surveillance at the following address: 900-2045 Stanley Street, Montreal, Quebec, H3A 2V4, or by email at cai.communications@cai.gouv.qc.ca.

The right of access to information is not absolute, and the firm may, in certain cases, be unable to provide certain personal information. For example, it cannot provide information that would reveal personal information about another person, confidential commercial information, or data protected by solicitor-client privilege or litigation privilege. If it is not possible to provide the requested information, the firm will inform the person in writing, explain the reasons why, and indicate the possible remedies.

9. Policy Amendments

The firm reserves the right to modify this Policy at any time. Changes will be posted on the firm's website.

10. Contact

If you have any questions or concerns regarding this Policy, please contact our Privacy Officer, at alice@raynardconsult.ca.