Vine and Williams Inc. Privacy Statement

At Vine and Williams Inc. (Vine and Williams), 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 Vine and Williams 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, to which all businesses must comply, effective January 1, 2004. As such we have tailored our own Privacy Practices to comply with the Privacy Act and to meet the specific needs and expectations of our clients.

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.

Collection

We may gather personal information from the following sources:

• From you, during a meeting to gather the necessary personal information to perform the professional service you require.
• From you, via contact forms or in writing.
• From bankers, lawyers and other financial service representatives with
  whom you have a relationship and have given consent to provide personal information to us.
• From past interactions with us.

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 Vine and Williams, we are accountable for your personal information. We will not sell, license, trade or rent your personal information to, or with, others.

• We are responsible for the protection of the personal information you disclose to Vine and Williams.
• We have appointed a Chief Privacy Officer to be accountable for our compliance with our Privacy Policy and regularly review our privacy policies and practices with our staff to ensure that we are consistently and constantly implementing them.
• 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 Vine and Williams’ 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 Vine and Williams. They will be required to protect the personal information disclosed by Vine and Williams 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.
• 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 Vine and Williams 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

Vine and Williams 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).

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 in an e-mail, at privacy@vine.on.ca. The firm will inform you of the implications in 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 Your Personal Information for Marketing Purposes

Vine and Williams will never disclose your personal information to a third party marketing firm. However, within the boundaries of our regulatory environment, from time to time Vine and Williams may make use of your personal information, with great discretion, to communicate and market our services and products to you.

Cookies

When you visit our Web site (www.vine.on.ca) 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. Cookies cannot be shared or stolen by other websites. They are private to our website and to the person visiting. It is Vine and Williams’ 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.

How We Protect Your Personal Information

Vine and Williams 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, Vine and Williams will employ generally accepted information security techniques, such as firewalls, and access control procedures, to protect personal information against loss and unauthorized access.

Retention of Your Personal InformationVine and Williams 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 Privacy 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.

Vine and Williams reserves the right to modify this Privacy Policy at anytime without notice.
Correcting or Updating Your InformationYou 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 Vine and Williams by email at: privacy@vine.on.ca.

Contact Us

Should you have any questions about Vine and Williams’ Privacy Policy or should you have reason to believe that Vine and Williams may have failed to adhere to this Privacy Policy, we ask that you contact us.  We will investigate all complaints. Address them to:

Privacy Officer
Vine and Williams
1 Hunter Street East,
Suite 100
Hamilton, ON
L8N 3W1