PRIVACY POLICY

Last Updated: 20 May, 2025

Harris & Partners Inc. (“Harris,” “we,” “us,” or “our”)  value the trust you place in us and we always respect your privacy. Please review carefully the following information as it describes how we manage and protect your personal information. Personal information is any information that can directly or indirectly identify “you” as an individual.

This Privacy Policy governs the personal information collected, used, and disclosed by Harris & Partners Inc. and its affiliated companies when you:

·       Visit our “Websites” operated by us or on our behalf.

·       Engage with us in other ways (during events, customer service, consultations or other interactions with us) or use our “Services” (our Website, and other related services, including any consultation, marketing, or events).

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

We will only collect, use, or disclose your information with your consent, which may be express or implied under certain circumstances, or as otherwise required or permitted under applicable law.

This Policy does not apply to any Harris’s employee information or ‘business contact information’ such as an employee’s name, title, business address, telephone number or email addresses that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession.

Please read this privacy policy carefully, as it will help you understand how we handle your information, your privacy rights, and how to contact us if you have questions.

Changes to this Policy

We reserve the right to update this Policy at any time and such modifications will enter into force on the date specified in the update. Please make sure to check for changes to this Policy. We will consider that you have accepted the changes to this Policy if you continue to provide personal information to us once the changes enter into force.

How we collect your information

Generally, Harris will collect personal information directly from you, and only to the extent necessary to provide our Services or to carry out our internal administrative operations.

We collect your personal information on our own behalf and on behalf of our affiliates.

We may collect personal information from you when:

·       you fill in an application form

·       have conversations with us over the telephone

·       e-mail us

·       ask us to contact you after visiting our website

·       have contact with us in person

The type of personal information we collect includes:

Information you give to us, or which is provided to us on your behalf, such as, payment and billing information and related documents, your name, email and physical address, social insurance number, driver’s license, or other identification documents .information, your date of birth, telephone number, employment information, information about your marital status and family, as well as other financial information pertaining to your assets, tax assessments, tax returns, and income.

We may also collection personal Information from third parties about your transactions with them or others, credit card usage, insurance coverage, transaction history, claims history, and level of indebtedness, and information from consumer reporting agencies, including credit reports.

We will use your personal information only for the particular purpose that you provided it, or for a directly related purpose. We may otherwise use your personal information where that other use is:

·       required or permitted by law; or

·       with your express or implied consent.

Your personal information may also be collected on our behalf by third parties, such as providers of technology services like order management platforms or newsletter management systems; consultants offering some of our client services; agencies responsible for answering questions or handling customer complaints.

How we use your personal information

We will only use your personal information for the purposes identified in this Policy or at the time of collection. These purposes include the following:

·         to administer your file and provide you our Services

·         to administer this Website

·         to access eligibility of debt relief services

·         to manage our business, including fulfilling contractual obligations

·         to administer your estate

·         to provide customer service and contact you in relation to Services being provided to you

·         with your consent, to send you updates on our Services and promotional material

·         to detect and prevent fraud

·         to comply with statutory or legal obligations

·         for any other purposes to which you have provided your consent

Disclosing your personal information to other parties

We will never sell your personal information. We do not share your personal information with other organisations unless you give us your express consent, or where sharing is otherwise required or permitted by law.

When we provide personal information to companies who perform services for us, such as specialist information technology companies, mail houses or other contractors to Harris, we require those companies to protect your personal information as diligently as we do. We have contractual and other means in place with those organizations in this regard.

We will also disclose your information:

·       To satisfy legal or contractual requirements.

·       If we are required to provide personal information in response to a legitimate court order, subpoena to submit documents or investigation by authorities or as otherwise required by applicable laws.

·       To help us collect a debt owed to us by you.

·       To complete certain statutorily mandated forms in the course of carrying out engagements where we are the “Trustee in Bankruptcy” or the “Trustee” or “Administrator” under a proposal, or receiver or monitor under the BIA.

·       We may share your information with our affiliates that are subject to this privacy policy, and they will only use or disclose your information for the purposes for which it was collected by us. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

·       If Harris sells its business or assets, in whole or in part, or is involved in a merger, as required by such a transaction, or as part of due diligence.

·       As required or permitted by applicable laws.

International Transfer of Information

Depending on the nature of the personal information, it may be stored in our offices in Ontario, as well as in the various computer systems in our offices, in our storage facilities, or in those of our service providers.

Your personal information may be transferred outside Canada or accessed from outside Canada, including the United States or India. Please note that information stored outside Canada will be subject to the laws of that jurisdiction, including potential access by local law enforcement.

If you have any questions about our use of service providers located outside of Canada, please contact our Privacy Officer (see contact details below).

Your Privacy Rights

You have the right to request access to the personal information you provide, and to correct or update your personal information. This right is subject to certain exceptions allowed by law. You also have the right to request the deletion of your personal information if it is outdated or not justified for the purposes it was collected.

If you submit a request to withdraw your consent to use or disclose your personal information, how we handle that request will depend on the situation and reasons.

·       You may withdraw your consent, but we will no longer be able to provide you a service or product that requires such consent; or

·       You may not withdraw your consent because processing your personal information is necessary or mandatory.

In either case, we may be legally required to retain certain personal information.

Any such request must contain sufficient details for us to be able to address it. We undertake to respond to any such request within a reasonable period of time, and to the extent possible, within a maximum of thirty (30) days, as set out in the applicable laws. We must, however, first verify the identity of the person making such a request.

We will ensure that your personal information is as accurate, complete and up-to-date as possible for the purposes for which it is used. However, it is your responsibility to advise us of changes to your personal information, such as your contact information.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us at hello@harrispartners.ca. You will then be removed from the marketing email list. However, we may still communicate with you, for example to send you service-related emails that are necessary for the administration of your estate to respond to service requests, or for other non-marketing purposes.

IP Addresses, Cookies and Third Party Analytics

Our web servers gather your IP address to help troubleshoot issues with our services, and to monitor the use of our site, including the location of our users.

Harris uses cookies to provide clients, potential clients and other site visitors with a better browsing experience.  These cookies collect information such as preferences and click activity for measurement and for features such as remembering your preferences.

Harris uses cookies and scripts in respect of advertisers to assist us in improving website performance, making business decisions, aiding in error reporting, and testing new functionality. These cookies and scripts collect non-personal information such as preferences and click activity for site analysis and measurement.  If you do not wish to have cookies active whilst you browse the Site you can “opt out” by modifying the privacy options in your browser. However, doing so will may limit your use of some of our website capabilities.

In order to better understand our users, Harris utilises third party measurement companies to assess site traffic. A tracking code is used to collect the information on the usage of the Site, including:

·       the number of page views (or page impressions) that occur

·       the number of unique visitors

·       how long these unique visitors (on average) spend on the site

·       common entry and exit points/pages into the site

This aggregated, non-personal information is provided to us to assist in analysing the usage of the site.

Information security

We are committed to keeping your trust by protecting the confidentiality, security, and integrity your personal information.

We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration.

We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law.

Data Retention

We retain the personal information we collect for as long as required to meet identified purposes, as long as it is reasonable to do so to settle your file, or for legal or commercial reasons. The retention period depends on the purposes and the nature of the information. On the expiry of this period, we permanently and securely destroy or anonymize the information in compliance with applicable legislation.

Addressing your concerns and challenging compliance

If you have any questions or concerns about our privacy practices or how to request information from us, please contact the Privacy Officer via email jay@harrispartners.ca or via regular mail to:

Harris & Partners Inc.
8920 Woodbine Avenue, Suite 104
Markham, Ontario L3R 9W9

If you not satisfied with our handling of your concerns, you may contact the following organizations responsible for the protection of personal information: the Office of the Privacy Commissioner of Canada (federal), toll free 1-800-282-1376 (toll-free) or, as applicable, the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Information and Privacy Commissioner of Alberta.