North & Company LLP
PAMAC Investments Inc.

Email: North & Company

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Protection of privacy is an important principle to North & Company LLP and Pamac Investments Ltd. We collect, use and disclose personal information responsibly and only to the extent necessary for the professional services we provide. Openness and transparency are key elements in how we handle personal information.

WHAT PERSONAL INFORMATION IS
Personal information is information about an identifiable individual. Included is information that relates to personal characteristics such as gender, age, income, home address or phone number, ethnic background, family status, health matters concerning history, conditions, and services received, or activities and views like religion, politics, opinions expressed by an individual, or opinions and evaluations of an individual. An individual's business address, telephone number, and position or title is considered business information and is not protected by privacy legislation.

WHO WE ARE
The law office of North & Company LLP has fourteen lawyers. Pamac Investments Ltd is our management corporation. We provide a wide range of professional legal services in Lethbridge, Alberta and in eight other locations in southern Alberta. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office maintenance, bookkeepers and accountants, a file storage company, temporary workers to cover holidays, credit card companies, website managers, our landlord and other lawyers. We restrict their access to any personal information we hold as much as is reasonably possible.

WHY WE COLLECT
PERSONAL INFORMATION: PRIMARY PURPOSES
Clients We collect, use and disclose personal information in order to serve our clients. One primary purpose for collecting personal information is to provide legal advice and services. For individuals, that information is about the client's legal issues including anything the client might have done or said that might affect their legal situation. We use this information to advise the client as to legal rights and responsibilities, and options for addressing the issues. We also use the information to assist us in carrying out our client's instructions. Another primary purpose usually involves collection of personal information from third parties about our client's legal issues so that we might determine how the third party's perception of the events possibly affects our client's legal situation. Yet another primary purpose is to obtain personal information so that we can contact our client at home in an emergency. Although rare for us to collect any personal information without the client's express consent, this might occur in a case of urgency or where it would be reasonable to believe the client would consent if asked and it is impractical to obtain consent. General Public We also serve our clients by collecting personal information about members of the general public. One primary purpose is to gather and review evidence that is relevant to a legal issue affecting our own clients. Often this collection, use and disclosure is done without the individual's consent because we are reviewing an apparent breach of law or an agreement and obtaining consent would compromise the investigation. Another primary purpose is to provide notice of special events or to make the general public aware of legal services our firm is prepared to offer. From our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us. Cookies are only used to help you navigate our website and are not used to monitor you. About Contract Staff Here our primary purpose for collecting personal information is to ensure we can contact them in the future and for necessary work-related communication. Rarely will we collect such information without prior consent. Exceptions might be in the case of a health emergency or to investigate a possible breach of law, or where it is reasonable to assume that consent would not have been withheld if sought. Investigations Often we act as investigators for professional regulators or associations or other business clients. Our primary purpose for collecting personal information in those instances is to gather the necessary information and evidence to express a sound opinion on the issue for our client. That may include representing them in legal proceedings. Here we often act without the consent of the subject of the investigation because we are inquiring into an apparent breach of law or an agreement and obtaining consent would compromise the investigation.

RELATED/SECONDARY PURPOSES
We also collect, use, and disclose information for purposes related to or secondary to our primary purposes. These include but are not limited to invoicing clients for professional services, including disbursements and taxes, processing credit card payments or collecting unpaid accounts, advising clients and others of new developments in the law, advising clients and others of our newsletters, courses we provide, and special offers and promotions that we have available. We regularly review client and other files to ensure that we continue to provide high quality services. Often external consultants may, on our behalf, do audits and continuing quality improvement reviews of our firm, including reviewing client files and interviewing our staff. Our lawyers are regulated by the Law Society of Alberta who may inspect our records and interview our staff as a part of its regulatory activities in the public interest. We are required to report serious misconduct, incompetence or incapacity of other practitioners. Also, our firm believes that it should report information suggesting serious illegal behaviour to the authorities. These reports could include personal information about our clients, or other individuals, although we try to keep this disclosure to a minimum. Also, various government agencies have the authority to review our files and interview our staff as a part of their mandates. Solicitor and client privilege restricts their access to much of this information. In these circumstances, we may consult with professionals who will investigate the matter and report back to us. On occasion the cost of some services provided by the firm to clients is paid for by third parties. They often have your direct or inferred consent or statutory authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to and responsible use of this funding. Clients or other individuals we deal with may have questions about our services after they have been received. Often we provide ongoing services for our clients over extended periods of time for which previous records are of assistance. Our internal policy is to retain client information for a minimum of ten years after the last contact to enable us to respond to those questions and provide future services. In the event that North & Company LLP/Pamac Investments Ltd or their assets were to be sold, the purchaser may want to conduct a "due diligence" review of the firm's records. This due diligence may involve some review of our accounting and service files but removal or recording of the personal information would be prohibited. Before providing access to the files, we would require the purchaser to enter into a confidentiality agreement. Only bona fide purchasers would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

HOW WE PROTECT PERSONAL INFORMATION
Protecting the personal information that we have collected is important. For that reason, we keep paper information and electronic hardware under supervision or secured in a locked area or one where access is restricted and our computers are password protected. Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies. Electronic information is transmitted through a direct line. We train our staff in the collection, use and disclosure principles expressed in this policy. Where we use outside consultants and agents and provide them with access to personal information, we require them to enter into privacy agreements with us.

WHY WE RETAIN AND
HOW WE DESTROY PERSONAL INFORMATION
As noted above, we need to retain personal information for some time to enable us to maintain our ongoing relationship with our clients and for our own accountability to external regulatory bodies. We attempt to balance those purposes with the intention of keeping personal information for the shortest period of time possible. As indicated, our internal policy is to keep our client files for about ten years. Our client and contact directories represent greater challenges in terms of systematic destruction, but we do remove original and dated information when we can if it does not appear that we will be contacting you again. Upon your written request, we will remove such contact information immediately. Personal information relating to our general correspondence with persons who are not our clients, newsletters, seminars and marketing activities are kept for about 12 months after the event is over. Paper files containing personal information are shredded. Electronic information is deleted and the hard drive is physically destroyed when hardware is replaced or discarded. Often we will send some or all of the client file to our client.

WHAT ACCESS YOU HAVE TO YOUR INFORMATION
With some legislated exceptions, you are entitled to see what personal information we hold about you. Upon your written request, we will help you identify and understand what records we might have about you. If we do not know you, we will need to confirm your identity before providing you with this access. We charge a nominal fee of $50.00 for such requests. If you require copies of the personal information, we also charge for photocopying at 25 cents per page. We will respond to your request within 45 days if at all possible by providing access or, by giving you the reason why we cannot provide you access. The most common reason for refusal would be that the personal information about you which we have has been collected for our client. This is usually protected by solicitor and client privilege. You cannot be given access to it without our client's permission. In the event that there is an error in the information, you are entitled to ask for a correction. This only applies to factual information and not to any professional opinions we may have formed or collected. If we mutually agree that an error has been made, we will make the correction and notify anyone to whom we have distributed the prior information. If we do not agree, we will still include in our file a brief statement from you and will forward that statement to anyone else who received that earlier information.

WHAT I DO IF I HAVE A QUESTION OR A COMPLAINT
Our Privacy Officer, Mr. Wayne C. Petersen, can be reached at: