VGlobal Immigration Inc.’s Commitment to Privacy

Protecting your privacy and the confidentiality of your personal information has always been an important aspect of VGlobal Immigration Inc.’s operations. As a provider of Canadian immigration services, the collection and use of customers’ personal information is fundamental to our day-to-day business operations. In fact, a law firm’s most important asset is its information.

We strive to provide you with the best customer service. To us, that includes treating your personal information fairly and with respect. Each of our employees and representatives must abide by our commitment to privacy in the handling of personal information. VGlobal Immigration Inc. is also concerned about the personal information of its employees and representatives.

Applicability of VGlobal Immigration Inc.’s Privacy Code

VGlobal Immigration Inc.’s Privacy Code informs you of our commitment to, and policy on, privacy. It tells you the ways we ensure that your privacy and the confidentiality of your personal information are protected.

In this Code, “we”, “us” and “our” means VGlobal Immigration Inc.. “You” and “your” means the individual who is a client or potential client of VGlobal Immigration Inc..

In other words, our Privacy Code applies to protect the personal information, in our possession and all clients of the VGlobal Immigration Inc., and users of our Web site.

However, this Code does not apply to personal information collected, used or disclosed by VGlobal Immigration Inc. for the purpose of operating the mandatory professional liability program for ICCRC or any other regulatory body from time to time.

Our website may contain links to other websites that are provided and maintained exclusively by third parties. Websites provided and maintained by third parties are not subject to this Privacy Code. Please review the privacy policies on those websites to determine their information handling practices.

What is Personal Information?

Personal information is any piece of information, either factual or subjective, about an identifiable individual.

Why do we collect Your Personal Information?

In general, VGlobal Immigration collects, uses, may need to disclose Personal Information about our clients and service providers in order to provide our clients with professional legal services. More specifically, we collect, use and disclose your Personal Information for the following purposes:

• to establish and manage client relationships, provide immigration consulting advice, perform legal services pertaining to the prevailing immigration laws, fulfill legal duties, and avoid conflicts of interest. This may include the sharing of Personal Information by and between VGlobal Immigration’s representative and affiliated partners or agents or companies for such purposes
• to share Personal Information to and from third parties for the purpose of providing immigration consulting services. Such third parties may include government agencies, parties in interest, foreign and other counsel and advisors, witnesses, decision-makers, or even experts
• to consider whether VGlobal Immigration should establish a commercial relationship with clients, suppliers and other third parties including issuing invoices, administer accounts, collect and process payments, and to fulfill retainer obligations
• to understand and respond to client or other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations or even promotions
• to develop, enhance, market, sell or otherwise provide VGlobal Immigration’s services
• to market, sell or otherwise provide services of third parties with whom Can-Am has a commercial relationship;
• to distribute our newsletters, blogs, facebook posts, conference information and other material includes brochures, e-flyers to individuals on our mail and e-mail lists, including via third-party/ agents mailing houses and email service providers
• to develop and manage our precedent systems and databases
• to develop and manage VGlobal Immigration’s business and operations
• to detect and protect VGlobal Immigration and its agents or associates against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with VGlobal’s policies and contractual obligations
• to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving VGlobal Immigration Inc. as permitted by, and to comply with, any legal or regulatory requirements or provisions and for any other purpose to which you consent.

To whom do we disclose Your Personal Information?

From time to time, VGlobal Immigration Inc. may disclose your Personal Information to:

• service providers or agents or associates, including an organization or individual retained by VGlobal Immigration to perform functions on its behalf, such as marketing, data processing, document management and office services
• an organization or individual retained by VGlobal Immigration to evaluate client’s worthiness or to collect outstanding on an account
• a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements or
• a person who, in the reasonable judgment of VGlobal Immigration is providing or seeking the information as your agentand to regulatory agencies such as ICCRC or others in connection with regulatory or other activities relating to the obligations of VGlobal’s and its practice of the profession of legal services and
• any third party or agents or parties, where you consent to such disclosure or where disclosure is required or permitted by the law.

The 10 Principles of Privacy

Our Privacy Code consists of the following ten key principles:

1- Accountability

At VGlobal Immigration Inc., we take our commitment to securing your privacy very seriously. Each employee and representative of VGlobal Immigration Inc. is responsible for the personal information under their control. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Code and related policies.

2- Identifying Purposes: Why We Collect Information

Whenever we collect information or establish a file about you, we will explain the purpose and how we intend to use the personal information we collect. We will do this either at that time of collecting personal information or earlier. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose.

We ask you for information and create and maintain a file about you to establish a relationship and serve you as your insurer. We obtain most of our information about you directly from you, or as required the regulatory bodies. In some cases, information may be obtained from an authorized representative or agent.

The information we ask for depends on which services you require from VGlobal Immigration Inc.. For example, we create and maintain a file with personal information about you in order to:

• evaluate your immigration needs
• determine which immigration programs or related services will meet those needs
• evaluate applications being submitted, particularly with respect to Canadian immigration and

administer Canadian immigration programs properly, including the handling and resolution of claims.

3-Consent

We seek and confirm your consent to collect, use and disclose your personal information at the time of collection or in advance. We will endeavour to employ clear, understandable language when we obtain your consent.

Consent may be expressed in writing or implied, and in some cases, you may provide it verbally, electronically or through your authorized representative. Written consent includes completing and signing an assessment form or another VGlobal Immigration Inc. service. Implied consent may be found where you choose to use a service of VGlobal Immigration Inc., such as one of our websites.

All electronic communication (“e-mail”) with you that is not essential to participation in a VGlobal Immigration Inc. service includes a straightforward “opt-out” feature that allows you to request that we cease e-mail communication with you. Not responding to our offer to have your name removed from the e-mail list is another form of implied consent.

Before deciding what form of consent is appropriate, VGlobal Immigration Inc. will consider the requirements of applicable law, the type of personal information it needs, the reason for its collection, use or disclosure and the type of customer contact that is involved. For example:

• where you file an immigration application with us through a designated representative, we may not have direct contact with you. Therefore, we are unable to obtain direct consent from you; or
• where there is a claim against a VGlobal Immigration Inc. client, there is usually a legal duty on us to defend that client’s interests. In order to fulfill that obligation, we must collect, use and disclose relevant personal information about third parties involved in the claim, even though the third parties have not given consent.

The choice to provide us with personal information is always yours. Upon request, we will explain your options of refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your written choices. However, your decision to withhold details may limit the services we are able to offer, whether at the time of application for immigration or later, such as upon receipt of a complaint.

Once you have provided client information, your ability to withdraw consent may be severely limited unless you completely cancel your application (which is regulated as per the Retainer Agreement you sign with us). This measure is necessary to protect the integrity of your immigration application. Furthermore, any refusing or withdrawing of consent is always subject to any overriding legal requirements or commitments.

4- Limiting Collection

Information is not collected by VGlobal Immigration Inc. without a specific, limited requirement. We collect information by fair and lawful means.

When you visit our website, information is not collected that could identify you personally unless you choose to provide it. You are welcome to browse our site at any time anonymously and privately, without revealing any personal information about yourself.

When you telephone VGlobal Immigration Inc., we may see your name on a “call display” feature. If you do not wish us to see your name, please contact your communication provider for instructions on blocking your identification from appearing or call us from a telephone number not associated with you.

5- Limiting Use, Disclosure and Retention

The immigration file we establish and maintain about you and the information we request from you is used/disclosed for the purposes defined. We will seek your consent before using or disclosing the information in the file for purposes beyond the scope of your original consent unless required/permitted by law.

Under no circumstances do we sell customer lists or other personal information to third parties for marketing purposes. VGlobal Immigration Inc.’s policy is to use personal information only to forward communications necessary or appropriate to the fulfillment of our obligations as a Immigration Firm. However, if you obtained one of our services through an agent, that agent may use your information for marketing or other purposes as permitted by applicable law. You should consult the agent(s) about their personal information practices.

There are some unavoidable types of disclosure of your personal information which may occur occasionally as part of VGlobal Immigration Inc. fulfilling its routine obligations and/or conducting its business in the ordinary course. This includes disclosure to, for example, partners, consultants and staff of VGlobal Immigration Inc., assuming that they are abiding by VGlobal Immigration Inc.’s Privacy Code (or their own code that provides generally equivalent protection) and only to the extent necessary to allow them to provide business services or support to VGlobal Immigration Inc., including technology, banking, financial, auditing, accounting, legal & insurance services & The Law Society of Upper Canada.

We will retain your information only for the time it is required for the purposes we describe and as permitted by applicable law. Once your personal information is no longer required, it will be destroyed or made anonymous. However, due to VGlobal Immigration Inc.’s ongoing exposure to potential claims and need for actuarial analysis, most information collected and aggregated is kept for a minimum of 6 years after completion of each service.

In addition, some personal information may be retained indefinitely because it is inseparable from records with historical or archival value.

6- Accuracy

All decisions involving personal information should be based on accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on individuals to disclose all material information and to inform us of any relevant changes.

We will make reasonable efforts to keep your information accurate and up-to-date, based upon satisfactory evidence provided by you and to the extent updated information is relevant to the purpose for which it was originally collected.

We regularly cross-check our name and address information for lawyers and other professionals with the Law Society of Upper Canada and other relevant provincial licensing bodies in the jurisdictions where we carry on business. We encourage our customers to review and confirm the accuracy of information provided. If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or Internet), and we will make the appropriate corrections immediately, upon receipt of appropriate evidence.

7- Safeguards: Protecting Your Information

We will protect your information with appropriate safeguards and security measures, such as VGlobal Immigration Inc.’s computer usage and security policies. Internal and external audits of our procedures and security measures are conducted regularly to ensure that they are being properly administered and that they remain effective and appropriate.

VGlobal Immigration Inc. maintains personal information in a combination of paper and electronic media. With respect to our business generally, recent paper records concerning individuals’ personal information are stored in files kept onsite at our head office.

Access to personal information will be authorized only for VGlobal Immigration Inc.’s employees and representatives who require access in the performance of their duties, to any person granted access by the individual through the consent process and to those otherwise authorized by law.

When providing information to agents acting on our behalf, we will require such organizations or individuals to abide by our Privacy Code or to have their own code which gives generally equivalent protection. We will give them only the information necessary to perform the services for which they are engaged, and will require that they not store, analyze or use that information for purposes other than to carry out those services.

VGlobal Immigration Inc.’s computer systems, including portions of our websites, are password-secured and constructed in such a way that only authorized individuals can access secure systems and databases. To safeguard against unauthorized access to your personal information via the Internet, you are required to “sign on” to certain secure areas of VGlobal Immigration Inc. websites using an individual, confidential password. Passwords to the VGlobal Immigration Inc. website is provided only upon verbal confirmation directly with the Regulatory Body’s member or by use of an electronic system which contains identity verification processes. Generic passwords are only employed where there is no confidential information being displayed on the screen by VGlobal Immigration Inc..

If you send us an e-mail message that includes personal information (such as your name included in the “address”), we will use that information to respond to your inquiry. Please remember that email is not necessarily secure against interception. If your communication is very sensitive, or includes information such as your bank account or credit card number, you should not send it electronically unless the e-mail is encrypted or your browser indicates that the access to our website is secure.

8- Openness: Keeping You Informed

VGlobal Immigration Inc. has prepared this plain-language Privacy Code to keep you informed. It is made available to the public on our website http://vglobal.ca

If you have any additional questions or concerns about privacy, we invite you to contact us by phone, fax, mail, e-mail, or our websites, and we will address your concerns to the best of our ability.

9- Providing Individual Access

We will give you access to the information we retain about you within a reasonable time, with a written request, satisfactory identification and proof of entitlement. You also have the right to know:

• how we collected your personal information;
• how we are using it; and
• to whom it may have been disclosed, except where such disclosure was to a governmental body or service provider to VGlobal Immigration Inc. for routine purposes. This would include, for example, auditors, reinsurers and accountants acting for VGlobal Immigration Inc..

If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or our websites), and we will make the appropriate corrections immediately, based on the receipt of satisfactory evidence.

In some cases, we may not provide access to personal information within our possession or control. This may occur when:

• providing access would be likely to reveal personal information about a third party or could pose a threat to the security of the third party, and the information cannot be segregated;
• disclosure would reveal confidential commercial information of VGlobal Immigration Inc.;
• it would be too costly, in our determination, to retrieve it;
• the personal information is protected by solicitor-client privilege; or
• the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons, such as a non-disclosure agreement.

If we deny your individual request for access to your personal information, we will advise you in writing of the reason for the refusal and you may then challenge our decision.

10- Providing Recourse: Respecting and Responding to Your Privacy Concerns

VGlobal Immigration Inc. encourages you to contact us with any questions or concerns you might have about your privacy or our Privacy Code. We will investigate and respond to your concerns about any aspect of our handling of your information.

In most cases, an issue is resolved simply by telling us about it and discussing it. You can reach VGlobal Immigration Inc. Customer Service by phone at 416-854-5921, by e-mail at info@vglobal.ca  or by mail at:

VGlobal Immigration Inc.

200-55

Village Center Place,

Mississauga, ON – L4Z 1V9

Canada

If, after contacting VGlobal Immigration Inc. Customer Service, you feel that your concerns have not been addressed satisfactorily, please contact the VGlobal Immigration Inc. Chief Privacy Officer at 416-854-5921, info@vglobal.ca, or by mail at the above address. Please be sure to include your name, address, preferred method of communication, the nature of your complaint, and relevant details, including your past communications with us.

If the issue is still not resolved satisfactorily, we will provide information on other complaint procedures that may be available to you.

Conclusions

Any changes to our Privacy Code and information handling practices shall be acknowledged in this Privacy Code in a timely manner. We may add, modify or remove portions of this Code when we feel it is appropriate to do so. You may determine when this Code was last updated by referring to the modification date found at the bottom of the page.

Version No.1; January, 2018

Last updated January 10, 2018