PRIVACY NOTICE

Effective Date: 2019 January 01

Scope and Overview

Sopow Law and Consulting (“SLC”) is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how SLC collects and uses personal information about you during and after your involvement with SLC. This Privacy Notice applies to current and former operators of SLC, and current and former contractors hired to assist with the business of SLC. This Privacy Notice applies to operators and contractors located in Canada.

This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of Canada. This Privacy Notice also describes your rights regarding the personal information that we hold about you and how you can access, correct, and request erasure of your personal information.

We will only use your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Collection of Personal Information

For purposes of this Privacy Notice, personal information means any information about an identifiable individual, as may be defined or limited under applicable privacy legislation. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. Personal information also excludes business contact details and job titles. To carry out our activities and obligations as SLC, we may collect, store, and use the following categories of personal information, which are required for us to administer our relationship with you:

· Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

· Date of birth.

· Gender.

· Emergency contact information.

· Government identification numbers such as driver's license number, health card number, or other identification card number.

· Performance information.

· Education and training.

· Employment records (including professional memberships, references, work history, and proof of work eligibility).

· Photographs.

· Results of background checks.

· Other personal details included in a resume or cover letter.

Use of Personal Information

We only use your personal information where applicable law permits it, or when the use is necessary to comply with a legal obligation that applies to SLC. We may use your personal information for the following legitimate purposes:

· Management and planning.

· Processing insurance claims.

· Accounting and auditing.

· Conducting performance reviews and determining performance requirements.

· Assessing qualifications for a particular job or task.

· Gathering evidence for disciplinary action.

· Complying with applicable law.

· Education, training, and development requirements.

· Complying with health and safety obligations.

We will only use your personal information for the purposes we collected it. If we need to use your personal information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may use your personal information without your knowledge or consent where required by applicable law or regulation.

Data Sharing

We will only disclose your personal information to third parties where required by law or to our contractors, designated agents, or third-party service providers who require such information to assist us with administering your relationship with SLC, including third-party service providers who provide services to us or on our behalf. These third-party service providers may be located outside of Canada.

We require all our third-party service providers to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to SLC. We do not permit our third-party service providers to use your personal information for their own purposes. We only permit them to use your personal information for specified purposes in accordance with our instructions.

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:

· To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.

· During emergency situations or where necessary to protect the safety of persons.

· Where the personal information is publicly available.

· For additional purposes with your consent where such consent is required by law.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of privacy protection as Canada, as necessary to assist us with administering your relationship with SLC, and for the purposes set out in this Privacy Notice.

Data Security

We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those agents, contractors, and other third parties that have a legitimate need for such access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate purpose without further notice to you or your consent.

Rights of Access, Correction, Erasure, and Objection

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your involvement with SLC. By law you have the right to request access to and to correct the personal information that we hold about you, or withdraw your consent to the use of your personal information under certain circumstances. If you want to review, verify, correct, or withdraw consent to the use of your personal information, please contact Nikolas Sopow at “nikolas@sopowlaw.com”.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Right to Withdraw Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact Nikolas Sopow at “nikolas@sopowlaw.com”.

Data Privacy Contact

If you have any questions about this Privacy Notice or how we handle your personal information, or would like to request access to your personal information, please contact Nikolas Sopow at “nikolas@sopowlaw.com”.

Changes to This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. We may use your personal information without your knowledge or consent where required by applicable law or regulation.