SHIBLEY RIGHTON LLP PRIVACY POLICY – FEBRUARY 1, 2012

Shibley Righton LLP (and its affiliate Longbar Management Services Limited Partnership) ("Shibley Righton" or "we") are committed to maintaining the security and privacy of personal information which we collect in accordance with applicable legislation. Shibley Righton offers and provides legal services and information to a wide range of clients. We collect, use and disclose personal information as necessary to offer and provide clients and potential clients with these legal services and information, and generally to fulfil our professional legal responsibilities and manage our business.

CONSENT

By providing us with your personal information, you consent to our collection, use and disclosure of that personal information as described in this policy. You may refuse to provide personal information to us, and you may, subject to legal or contractual restrictions and reasonable notice, withdraw your consent at any time to the continued use and disclosure of personal information previously collected by us. The withdrawal of consent may have legal consequences or prevent Shibley Righton from providing legal or other services to you.

Canadian privacy legislation defines "personal information" broadly as information about an identifiable individual, or information that allows an individual to be identified. Generally speaking, personal information does not include your business contact information such as your name, title or position, business address, telephone number, fax number or email address. The type of personal information which Shibley Righton may collect about you includes your name, home address, telephone number, personal email address, billing and account information, information about a legal issue, and other information related to providing legal advice and services to you.

HOW WE MAY USE YOUR PERSONAL INFORMATION

We collect and use personal information:

To determine whether Shibley Righton can act for you, including to identify conflicts of interest; To offer and provide legal services to you, and to communicate with you about our firm and our services; To administer our client records and to bill for legal services; To fulfil our legal and professional obligations; As permitted or required by law or for purposes for which you otherwise provide your consent.

Shibley Righton uses personal information about clients for the provision of legal advice, including obtaining and carrying out client instructions, reporting and communicating with clients, billing and accounting, and protecting against fraud, illegal activities or error. Shibley Righton may also use your personal information to send you newsletters and information about our services, or about legal developments and issues that we think would be of interest to you. We may also use your personal information to invite you to client functions, seminars and other events. If at any time you wish not to receive such communications, you may ask us to remove you from our distribution lists.

If you send personal information through our firm website, we may use it to assess website use and traffic, and to respond to your questions and comments.

DISCLOSURE OF PERSONAL INFORMATION

As lawyers, we have a professional obligation to keep confidential all information we obtain within a lawyer-client relationship.

We disclose clients' personal information only in accordance with this policy or as otherwise permitted or required by law. In order to provide legal services to our clients, we may disclose your personal information to our affiliates and to third parties for purposes such as the following:
To third parties when it is necessary to do so to provide legal services to you, e.g., when we retain an expert consultant or other law firm or agent on your behalf; To service providers retained by us to assist us with marketing or other services, including technical support and mailing; To third parties to assist us in evaluating your credit-worthiness or to collect debts outstanding on an account; To anyone who we reasonably believe is your agent; To our insurers and to regulatory agencies in connection with regulatory or other activities relating to the obligations of Shibley Righton and its professional responsibilities in relation to the practice of law; and * To a third party or parties, where you consent or where such disclosure is required or permitted by law.

Your personal information may be accessed or stored in Canada or another jurisdiction, in which case it will be subject to the laws of that jurisdiction.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Your personal information is kept in secured locations and on servers controlled by Shibley Righton LLP, located at our offices or at the offices of our service providers.

We use safeguards typical of those in the legal profession to protect the security of your personal information in our possession, including procedural, organizational and physical measures. Where your personal information is sent to a third party for processing, we ensure that the third party is obligated to keep your personal information secure.

RETENTION OF PERSONAL INFORMATION

Shibley Righton retains personal information for as long as it is needed for the purposes for which it was collected and used. On completion of a matter, clients should advise us what information and additional documentation they require. Any information and documentation that our clients or others have provided to us together with our work product will be dealt with in accordance with our records retention policy from time to time, and such material may be destroyed after an appropriate period of time.

PRIVACY ON THE SHIBLEY RIGHTON WEBSITE

Some personal information may be collected on the Shibley Righton LLP website without your directly providing the information. For example, some information about internet users' traffic patterns is automatically collected and linked to users' Internet Protocol addresses. In appropriate circumstances such as investigation of a security breach, the IP address may be used with the cooperation of the ISP to locate and identify an individual using the website.

Server logs log information about visits to our website. This information is used to improve our website. We do not link this information to other data so as to identify individual visitors except for security purposes.

Our website may contain links to other websites. We strive to make sure that websites linked to our own meet our standards including those with respect to privacy. However, we are not responsible for the content of other websites or for their privacy practices.

ON-LINE COMMUNICATIONS

Visitors to our website may voluntarily submit personal information to us to ask a question, request information, download a publication, or communicate with Shibley Righton in some other way. Visitors should be aware that such communications, and email communications in general, may not be secure. Visitors should also be aware that delivery of electronic communications may be delayed or prevented by our anti-spam software or network failures, and Shibley Righton will have no responsibility for the consequences of such failed communication.

CHANGES TO THIS PRIVACY POLICY

Shibley Righton reserves the right to amend this privacy policy at any time. If we make a change to this privacy policy, we will post such changes on our website and make the revised policy and changes available upon submission of a request to our Privacy Officer.

ACCESS TO YOUR PERSONAL INFORMATION

You can ask to review your personal information held by Shibley Righton by writing to our Privacy Officer, whose address is shown in this policy. You can ask that corrections be made if the information we possess is inaccurate. Please note that you may not be permitted to view your records if the disclosure of your records would cause security, legal or confidentiality concerns.

MORE INFORMATION – PRIVACY OFFICER

Shibley Righton's Privacy Officer is Stacey Chandler. If you have any questions or concerns about this privacy policy, or about the handling of your personal information, please contact our Privacy Officer at:

Privacy Officer
Shibley Righton LLP
700 – 250 University Avenue
Toronto, Ontario M5H 3E5
Telephone: (416) 214-5280
Fax: (416) 214-5480
Email: stacey.chandler @shibleyrighton.com

LEGAL DISCLAIMER

None of the material on this website is offered, nor should be construed, as legal advice. Access to this material, its transmission or receipt, or any communication with us by email or otherwise, does not create a solicitor-client relationship with Shibley Righton or with any of the firm=s lawyers. Such a relationship would require direct, personal contact between you and our firm through one or more lawyers, and would also require a retainer agreement that confirms that such a relationship is established and the terms of that relationship. You should not act or rely upon information contained in this material without specifically seeking professional advice.

This site may offer links to other resources on the internet as a convenience to our readers. We do not take any responsibility for the content, accuracy or timeliness of those other sites, nor do we endorse any commercial products that may be advertised or available on those sites.

You may display, download and print a copy of material from the Shibley Righton website for non-commercial, personal or educational purposes provided that you do not modify the content and each copy acknowledges that Shibley Righton or the person shown as the copyright holder is the source and holds the copyright. No part of any document on the Shibley Righton website may be reproduced or transmitted for any other purpose.

February 1, 2012