What personal information do we collect?

Personal information is any information that identifies you, or by which your identity could be deduced.
If we did not collect and use your personal information, we could not provide you with legal services.

How do we collect your personal information?

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, both at the start of a retainer and in the course of our representation.

Sometimes we may obtain information about you from other sources, for example:
� your insurance company;
� your real estate agent in a property transaction;
� from a government agency or registry;
� your employer, if we are acting for you, at its request;
� your accountant.

Use of Your Information

We use your personal information to provide legal advice and services to you, to administer our client (time and billing databases) and to include you in any direct marketing activities. If you tell us that you no longer wish to receive information about our services, or about new developments in the law, we will not send any further material.

Kramer Simaan does not disclose your personal information to any third party to enable them to market their products and services. For example, we do not provide our client mailing lists to other law firms.

Disclosure of your Personal Information

Under certain circumstances, Kramer Simaan will disclose your personal information:
� when we are required or authorized by law to do so, for example if a court issues a subpoena;
� when you have consented to the disclosure;
� when the legal services we are providing to you requires us give your information to third parties (for example a lender in a real estate mortgage transaction) your consent will be implied, unless you tell us otherwise;
� where it is necessary to establish or collect fees;
� if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy;
� if we engage expert witnesses on your behalf;
� if we retain other law firms at your request, and on your behalf;
� if the information is Publicly Available Personal Information, as it is defined under the Personal Information Protection and Electronic Documents Act.

Updating Your Information

Since we use your personal information to provide legal services to you, it is important that the information be accurate and up-to-date.
If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?

Kramer Simaan takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
� premises security;
� restricted file access to personal information;
� deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
� internal password and security policies.

Access to Your Personal Information

You may ask for access to any personal information we hold about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Correcting Errors

If Kramer Simaan holds information about you and you can establish that it is not accurate, complete and up-to-date, the firm will take reasonable steps to correct it.

Can I be denied access to my Personal Information?

Your rights to access your personal information are not absolute. We may deny access when:
� it is required or authorized by law (for example, when a record containing personal information about you is protected by solicitor-client privilege);
� to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;
� to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or
� the information was generated in the course of a formal dispute resolution process.

Can I request anonymity?

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website). The Act requires us to confirm the identity of all new clients. It may also require us disclose information to FINTRAC in relation to certain large cash transactions.

Credit Bureaus

To help us make credit decisions about clients, prevent fraud, check the identity of new clients and prevent money-laundering, we may – with your consent – request information about you from the files of consumer reporting agencies.

Communicating with Us

You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.

Our practice is to communicate with you by email, rather than by mail or fax.  It is less expensive for you if we communicate in this fashion.  If you do not wish us to communicate with you by email, you must advise us.

Changes to this Privacy Policy

Since Kramer Simaan regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access

If you have any questions, or wish to access your personal information, please write to our Privacy Contact at the firm address.  Our Privacy Contact is Jeff Kramer.

Our website may contain links to other sites, which are not governed by this privacy policy.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.