PRIVACY POLICY

Toogood Financial Systems Inc. is committed to the proper management of the personal information of its clients and other parties that it collects in the course of its business.

In providing services to clients, we have a contractual and professional obligation to maintain the confidentiality of information that we receive. The practices set out in this privacy policy (the "Policy") seek to balance the individual's right to the privacy of his or her personal information and Toogood's need to collect, use or disclose personal information for legitimate business purposes.

We will continue to review our personal information management practices and improve them as necessary to better protect the privacy of individuals. This Policy was last amended on the date shown at the end of the Policy.

What Is Personal Information?

Personal information means any information that can be used to identify you as an individual, including your name, personal telephone number and address, email address, information in your resume or about your employment, the matter about which you retained or contacted Toogood, your account with us and any other information that you choose to provide to Toogood. Personal information does not include corporate information or so called business card information such as your business address or telephone number in your capacity as an employee of an organization.

Your Consent

By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.

We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the products or services requested. The form of the consent that we will seek before collecting, using or disclosing personal information may vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent and opt-out consent. We will consider the sensitivity of the information and the individual's reasonable expectations in determining how consent must be given.

You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its purpose to Toogood. Toogood will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude Toogood from providing services.

Collection of Personal Information

We will not collect personal information indiscriminately. We will limit the amount and the type of information we collect to that necessary to fulfill the purposes we have identified to you, or as otherwise permitted or required by law. We may also collect information about your business and business interests or your personal interests to better serve you and foster our relationship.

When possible, we will collect personal information from you directly. However, to provide legal services to clients or for legal, administrative, marketing or management purposes, we may also collect personal information through outside sources such as credit bureaus, government agencies or institutions or through other third parties such as employment and other references, employers and service providers.

Use of Personal Information

We use personal information only as described in this Policy or as otherwise permitted or required by law. Before your personal information is used or disclosed for a new purpose, we will ask for your consent unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law.

Toogood generally uses personal information about clients for the provision of service, including obtaining and carrying out client instructions, reporting and communicating with clients, billing and accounting, and protecting against fraud, illegal activities or error. Toogood may also use your personal information to send you newsletters about our services or about developments that we think would interest you. To establish or enhance our relationship, we may invite you to client functions, seminars and sporting or cultural events.

We regularly distribute client memos, practice group bulletins, articles and other updates and publications to people on our mailing lists, who can elect to receive materials on one or more subject matters. At any time, you may change your preferences and mailing option (regular mail or email), or unsubscribe from our mailing lists.

Disclosure of Personal Information

We disclose personal information only as described in this Policy or as otherwise permitted or required by law. To provide services, we may sometimes disclose our clients' personal information to Toogood's affiliates, foreign agents and government or regulatory agencies. At times we may also disclose personal information to service providers, inside or outside Canada, that assist us with marketing or other services, including technical support and mailing. We limit the service provider's right to use the personal information only for the services it provides to us, and we require the service provider to maintain the confidentiality of the personal information and to take steps to protect the security of the personal information we give it.

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

Retention of Personal Information

Toogood will retain information, including personal information, for as long as it is needed for the purposes for which it was collected. For example, if you send us personal information electronically to apply for employment with Toogood, we will retain your personal information for a reasonable period to permit future consideration for employment. Toogood may also be subject to legislative requirements regarding the retention of certain types of information.

Protection of Personal Information

We use the standard safeguards of the legal profession to protect the security of personal information in our possession, including physical, organizational and technological measures.

Your Access to Your Personal Information

You can ask to view your personal information by writing to the Privacy Compliance Officer, whose address and link are provided at the end of this Policy. You can request that corrections be made where you can show that the information we possess is incorrect or incomplete. Please note that under certain circumstances, you may not be permitted to view your records, such as where the disclosure of your records would cause security, legal or confidentiality concerns.

Links to Other Websites

Our Web Site does not collect any information from its visitors, but may contain links to other websites. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the content or privacy practices of other websites. We strongly encourage all Site visitors to review the privacy statements and policies of all external websites.

More Information About Toogood's Privacy Practices

Please contact Toogood's Privacy Compliance Officer with any questions or concerns you have about this Policy or Toogood's handling of your personal information. We will investigate and respond to your concerns.

Privacy Compliance Officer
1725 Sixteenth Avenue
Richmond Hill, Ontario
Canada L4B 4C6

January 2006