Privacy Policy

At Arra Law Firm, we are committed to maintaining the accuracy, confidentiality and security of your personal
information. This Privacy Policy describes the personal information that Arra Law Firm collects from or about you,
how we use and to whom we disclose that information.

Arra Law Firm has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain
groupings of individuals. This Privacy Policy applies to the personal information of all individuals, unless the personal information is related to an individual who seeks to be, is or was employed by Arra Law Firm. Such
information is dealt with in the Arra Law Firm’s Employee Privacy Policy.

If you are unsure of which Privacy Policy applies to you, please contact our Privacy Officer for more information.

It is Arra Law Firm’s policy to comply with the privacy legislation within each jurisdiction in which we operate.
Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to
another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and
provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in
this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how
this Privacy Policy applies to you, please contact our Privacy Officer for more information.

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual,
other than the person’s business title or business contact information when used or disclosed for the purpose of
business communications.

What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact.
This includes:

 contact and identification information, such as your name, address, telephone number and email

address;
 product-and-service related information concerning the products and services that we provide to, or
receive from, you;

 credit and financial information, such as your direct deposit and banking information; and

 business relationship information, including information related to your agreements, preferences,
advisors and decision-makers, as well as any feedback and information requested by or provided to you.

We may also collect market-related information, which may include personal information, concerning market trends
and activities impacting our business. This information may include contract terms, financial information and other
information for the purpose of market analysis and strategic planning. We may also collect information related to
our media, investor and public relations activities and information related to our interactions with financial and other
analysts and advisors.

As a general rule, Arra Law Firm collects personal information directly from you. In most circumstances where the
personal information that we collect about you is held by a third party, we will obtain your permission before we
seek out this information from such source (such permission may be given directly by you, or implied from your
actions).

From time to time, we may utilize the services of third parties in our business and may also receive personal
information collected by those third parties in the course of the performance of their services for us or otherwise.

Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they
have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you
without your knowledge or consent.

Why Do We Collect, Use and Disclose Personal Information?

Arra Law Firm collects personal information to enable us to manage, maintain and develop your legal case(s) and/or
our firm and operations, including:

to establish, maintain and manage our relationship with you so that we may provide you with, or receive

from you, the legal services that have been requested (for example, we will use your personal
information to establish and verify your identity and location so that we may provide you with the
services that you have requested);

to review the services that we provide to you so that we may understand your requirements for our legal

services and so that we may work to improve our services;

to review the products and services that we obtain from you so that we may work with you and so that

you may understand our requirements for such products and services;

to comply with your requests (for example, if you prefer to be contacted at a business or residential

telephone number and advise us of your preference, we will use this information to contact you at that
number);

to protect us against error, fraud, theft and damage to our goods and property;
to enable us to undertake our environmental, health and safety activities, including incident planning,

response and investigation;

to enable us to comply with applicable law or regulatory requirements (for example, we may collect

personal information to satisfy the obligations imposed on us by The Law Society of Ontario and
The Office of the Privacy Commissioner of Canada); and

any other reasonable purpose to which you consent.

How Do We Use and Disclose Your Personal Information?

We may use or disclose your personal information:

for the purposes described in this Privacy Policy; or
for any additional purposes for which we have obtained your consent to the use or disclosure of your

personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or
required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties who require
such information to assist us with managing our relationship with you, including: third parties that provide services
to us or on our behalf; third parties that assist Arra Law Firm in the provision of services to you; and third parties
whose services we use to conduct our business.

In addition, personal information may be disclosed or transferred to another party during the course of or completion
of, a change in ownership of or the grant of a security interest in, all or a part of Arra Law Firm through, for
example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that

such party is bound by appropriate agreements or obligations and is required to use or disclose your personal
information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent
otherwise.

Further, your personal information may be disclosed:

 as permitted or required by applicable law or regulatory requirements;
to comply with valid legal processes such as search warrants, subpoenas or court orders;

 as part of Arra Law Firm’s regular reporting activities;

 to protect the rights and property of Arra Law Firm;
during emergency situations or where necessary to protect the safety of a person or group of persons;

 where the personal information is publicly available; or

 where required by law, with your consent.

Your Consent Is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so.
Depending on the sensitivity of the personal information, your consent may be express, implied or deemed (using an
opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent
that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with
us, we will assume your consent to the collection, use and disclosure of your personal information for purposes
related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances,
your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we
plan to use or disclose your personal information for a purpose not previously identified (either in
this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.
As we have described above, we may collect, use or disclose your personal information without your knowledge or
consent where we are permitted or required to do so by applicable law or regulatory requirements.

Deemed Consent (Opt-Out)

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable
notice, by contacting our Privacy Officer using the contact information set out below. All communications with
respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of
your personal information as explained in this Privacy Policy.

How Is Your Personal Information Protected?

Arra Law Firm endeavours to maintain physical, technical and procedural safeguards that are appropriate to the
sensitivity of the personal information in question. These safeguards are designed to prevent your personal
information from loss and unauthorized access, copying, use, modification or disclosure.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal
information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead
append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information,
please contact our Privacy Officer. Please note that any such communication must be in writing. Generally, your
information is kept at our corporate offices in Mississauga, Ontario, Canada (see address information below).

When requesting access to your personal information, please note that we may request specific information from
you to enable us to confirm your identity and right to access, as well as to search for and provide you with the
personal information that we hold about you. We may charge you a fee to access your personal information;
however, we will advise you of any fee in advance. If you require assistance in preparing your request, please
contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where
applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal
information that we hold about you. In addition, the personal information may have been destroyed, erased or made
anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you
of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or have any concerns about how we manage your personal
information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavour to answer
your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our
response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for
our Privacy Officer is as follows:

Anisa Arra, 201-5025 Orbitor Drive, Building 6, Mississauga, ON L4W 4Y5 Canada

Phone: 905-629-2764 Email: anisa@arralawfirm.com Fax: 905-491-6974

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory
obligations or in the manner in which we deal with your personal information. We will post any revised version of
this Privacy Policy on our website www.arralawfirm.com and we encourage you to refer back to it on a regular
basis. This Privacy Policy was last updated on February 7, 2022.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer.
This Privacy Policy includes examples but is not intended to be restricted in its application to such examples;
therefore where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Arra Law Firm any
obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and
provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between
this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be
interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.