Privacy Policy

1. PIPEDA Compliance

Since January 1, 2004, all Canadian organizations engaged in commercial activities — including law firms — have been required to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Canadian Standards Association Model Code for the Protection of Personal Information incorporated by reference into PIPEDA.

Ontario does not have a substantially similar private-sector privacy law, and therefore PIPEDA applies fully to NGW Law’s commercial activities. PIPEDA is founded on 10 fair information principles:

1. Accountability
2. Identifying Purposes
3. Consent
4. Limiting Collection
5. Limiting Use & Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance

NGW Law has designated its principal lawyer as the Privacy Officer responsible for ensuring compliance with PIPEDA and this Policy.

2. Information We Collect

We collect personal information that is necessary to provide legal services and to fulfill our obligations under the law. We collect only what is reasonably required — no more.

3. Purposes of Collection

We identify the purpose for which personal information is collected before or at the time of collection. We use personal information for the following purposes:

• Providing legal advice and professional services pursuant to a retainer agreement
• Conducting conflict-of-interest checks before accepting a new matter, as required by the Law Society of Ontario
• Client identification and verification, including for anti-money laundering compliance under FINTRAC regulations (PCMLTFA)
• Administering client files, billing records, and trust accounts
• Communicating with clients, courts, government agencies, opposing counsel, and other parties about a matter
• Registering documents with Land Registry, the Ontario Business Registry, and other public authorities
• Complying with legal and regulatory obligations, including Law Society reporting requirements
• Responding to general legal inquiries submitted through our website

We will not use personal information for any purpose other than those identified above without first seeking additional consent, or as otherwise permitted or required by law.

4. Consent

In most cases, we obtain your consent before collecting, using, or disclosing your personal information. Consent may be express (written or oral) or implied through your conduct and the nature of the retainer.

When you retain NGW Law to act on your behalf, you generally provide implied consent to our collection and use of personal information reasonably necessary to provide the legal services requested. For example, if you retain us to complete a real estate purchase, you consent to our sharing relevant information with the lender, Land Registry, and other parties necessarily involved in the transaction.

5. Disclosure of Personal Information

NGW Law does not sell, rent, or trade personal information to third parties for marketing purposes. We may disclose personal information only in the following circumstances:

• —With your consent — when you have expressly or impliedly authorized the disclosure
• —Legal requirements — when required or authorized by law, including pursuant to a court order, subpoena, or other compulsory legal process
• —Law Society obligations — to comply with reporting obligations to the Law Society of Ontario as our governing regulatory body
• —Transaction requirements — to third parties necessarily involved in the legal matter, such as lenders, title insurers, opposing counsel, real estate agents, or government registries
• —FINTRAC compliance — to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as required under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• —Service providers — to trusted third parties who assist in operating our practice (e.g., cloud storage, document management, accounting), bound by confidentiality obligations consistent with this Policy
• —Fee collection — to the extent necessary to collect outstanding fees and disbursements
• —Estate or succession matters — in the event of the lawyer's incapacity, retirement, or death, to ensure client files are properly handled pursuant to Law Society rules

6. Safeguards

NGW Law takes reasonable physical, organizational, and technical measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. Our safeguards include:

• Secure, password-protected file management systems and encrypted cloud storage
• Confidentiality obligations binding all lawyers and staff as part of our professional and employment obligations
• Restricted access to client files on a need-to-know basis only
• Secure disposal of physical documents containing personal information
• Firewalls, antivirus software, and other technological safeguards for electronic records

7. Retention of Information

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, accounting, or reporting requirements.

Client files are retained for a minimum of ten (10) years following the conclusion of a matter, or longer where required by law or professional obligation (for example, real estate transaction documents or corporate records may be subject to longer statutory retention requirements). The Law Society of Ontario’s Rules of Professional Conduct and LSRS regulations govern our file retention obligations.

When personal information is no longer required, we destroy or de-identify it in a secure manner appropriate to its sensitivity.

8. Your Rights & Access

Subject to certain legal exceptions, you have the right to request access to the personal information we hold about you and to request corrections if that information is inaccurate, incomplete, or out of date.

Where access is denied, we will provide written reasons. You may challenge our refusal by contacting the Office of the Privacy Commissioner of Canada.

9. Website & Cookies

Our website may collect certain information automatically through server logs, including IP addresses, browser type, pages visited, and time of visit. This information is used in aggregate to improve website performance and security and is not linked to any personally identifiable information.

10. Solicitor-Client Privilege & Confidentiality

As lawyers governed by the Law Society of Ontario, NGW Law and all lawyers at the firm are subject to a strict professional and ethical duty of confidentiality. All information received from a client within the solicitor-client relationship is confidential and is subject to solicitor-client privilege.

Solicitor-client privilege belongs to the client, and NGW Law will not disclose privileged communications without client authorization except where required by law or where permitted by the Rules of Professional Conduct (for example, to prevent imminent bodily harm).

11. Updates to This Policy

NGW Law reviews this Privacy Policy periodically and may update it to reflect changes in our practices, legal requirements, or regulatory obligations. We will post the updated Policy on our website with a revised effective date. Material changes affecting how we handle personal information will be communicated directly to affected clients where reasonably practicable.

Continued use of our services or website following a material update constitutes your acceptance of the revised Policy.

12. Contact Our Privacy Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer: