General Privacy Policy

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Internet Privacy Policy

  Accountability

Davidson is accountable for all personal information in our possession or control. This includes any personal information that we receive directly, for example, from individual clients, partners and employees as well as individuals' personal information that we may receive indirectly, for example, through corporate and government clients.

We will not sell, license, trade or rent your personal information to, or with, others. We have established policies and procedures aimed at protecting personal information and have appointed a Privacy Partner to oversee privacy issues for Davidson who is ultimately accountable for ensuring Davidson's compliance with this general privacy policy. This Privacy Partner may, from time to time, designate one or more other individuals within Davidson to act on his or her behalf. If you have questions about our privacy practices, you are free to contact the Privacy Partner at privacy@Davidson-Co.com .

Davidson is also responsible for personal information that has been transferred to a third party for processing. We may transfer personal information to third parties for reasons, such as data warehousing or administrative services, where the third parties do not make any independent use of the personal information. Davidson will use contractual or other means to require such parties to commit to protecting personal information to a level comparable to that provided by Davidson.

Identifying Purpose

Davidson will identify the purposes for which personal information is collected at or before the time it is collected. The purposes for which information is collected, used or disclosed by Davidson must be those that a reasonable person would consider are appropriate in the circumstances. When Davidson uses personal information that has been collected for a purpose not previously identified, it will identify the new purpose for the individual to whom the personal information relates prior to using the information in that manner, except as permitted or required by law.

Client Personal Information

  In most instances, Davidson will collect, use or disclose personal information only to provide professional services to you. Each engagement letter includes an explanation of why we require information, what use will be made of it and with whom it may be shared in order to provide our professional services.

Your personal information may be disclosed internally for the purpose of determining compliance with applicable professional standards, internal policies or in the performance of quality reviews. Personal information may also be shared internally in order to allow us to offer services or products that may be of interest to you.

In accordance with professional standards, if you are an audit or attest client, personal information may be shared with the audit or attest engagement team and other personnel so that it may be used in the audit or attest engagement.

Partner and Employee Personal Information

  We also collect personal information from our partners and employees in order to pay them, comply with laws, provide them with benefits, administer performance management tools and to improve on programs, policies and employee relations. In certain cases, we may also aggregate partner and employee personal information to provide business metrics and evaluate the effectiveness of our human resources programs. In these circumstances, the information is not identifiable with any individual.

We also collect personal information from individuals seeking employment with Davidson.

Consent

Davidson collects personal information about you only when you voluntarily provide it. Typically, we will seek your consent for the use or disclosure of your personal information when we collect it. In certain circumstances, your consent may be sought after the information has been collected but before we use it (i.e. when we want to use information for a purpose not previously identified). We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected. However, we may use personal information without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual or where permitted or required by law (i.e. when information is being collected for the detection and prevention of fraud, seeking the consent of the individual might defeat the purpose of collecting the information). Furthermore, your consent will remain valid after termination of our relationship with you.

To make the consent meaningful, Davidson will ensure the individual is advised of the purposes for which the personal information is used or disclosed in a reasonably understandable manner. The form and manner of obtaining consent may vary from express written consent to implied consent, depending upon the circumstances and the type of information.

Client Personal Information

  The terms and conditions of every professional services engagement are documented in each engagement letter and include a discussion about how Davidson may use and disclose your personal information. By signing the engagement letter, you will be providing your consent to the collection, use and disclosure described in the terms and conditions.

You always have the option not to provide your consent to the collection, use and distribution of your personal information, or to withdraw your consent at a later stage; however, in these cases, we may not have sufficient information to provide you with our services.

Partner and Employee Personal Information

  Forms and applications used to provide human resources-related services to partners and employees will describe the purposes for which personal information is required and with whom it will be shared and will allow for you to consent to the collection, use and disclosure as described.

Employment candidates will also be advised of the purposes for which their personal information is being collected and you will be provided an opportunity to consent to the collection, use and disclosure as described.

You always have the option not to provide your consent to the collection, use and distribution of your personal information or to withdraw your consent at a later stage; however, in these cases, we may not be able to employ you or to provide you with benefits.

Limiting Collection

We will limit, where possible, the collection of client and employee personal information to fair and lawful means and to that which is required to provide our services or operate our business (i.e. for purposes that a reasonable person would consider appropriate in the circumstances).

The information we collect, which may include personal information, may involve at least some of the following:

• Contact information (such as name, nicknames, titles, business names, business addresses, email work addresses, work or cell telephone numbers); and
• Financial status and billing information (such as credit card numbers/expiration dates and credit history).

  Limiting Use, Disclosure and Retention

Use of Personal Information

We use your personal information to:

• Provide you with timely and reliable professional assurance, tax or advisory services;
• Do all the things necessary to administer those services;
• Research, develop, manage, protect and improve those services;
• Develop and maintain our relationship with you and communicate with you;
• Advise you about new products and services that may be of interest to you; and
• Invoice and collect payment for professional services and products provided by us to you.

Disclosure of Personal Information

We reserve the right to disclose personal information without consent to:

• Comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies;

• A government institution that has requested the information, and after identifying its lawful authority, has indicated that disclosure is for the purpose of enforcing, carrying out an investigation or gathering intelligence relating to: i) any federal, provincial or foreign law; ii) a suspicion that the information relates to national security or the conduct of international affairs; or iii) is for the purpose of administering any federal or provincial law;
• An investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement or a contravention of a federal, provincial or foreign law or we suspect the information relates to national security or the conduct of international affairs; and
• A third party in the event of an actual merger or acquisition of Davidson so that you may continue to receive the same professional services from the new entity or third party. In this unlikely case, the use of your personal information by the new entity would be limited to the purpose(s) for which we originally used the information.

Davidson will never disclose your personal information to a third party marketing firm. However, within the boundaries of our regulatory environment, from time to time Davidson may make use of your personal information, with great discretion, to communicate and market our services and products to you. You can choose not to receive any invitations or direct mail from us by indicating your preference to the Privacy Partner at privacy@Davidson-Co.com .

Retention of Personal Information

Davidson will retain your personal information for the period of time necessary to fulfill the purpose(s) for which it was collected, to comply with applicable laws and regulations and to adhere with Davidson's document retention policies. These policies take into account the rules of professional conduct, which govern the practice of public accounting, and any applicable legal or regulatory requirements. Further, personal information no longer required to fulfill its identified purposes will be destroyed, erased or made anonymous in a secure manner in accordance with Davidson's document retention policies.

Davidson retains personal information about current and past partners and employees in accordance with employment laws and standards. Personal information collected from individuals seeking employment with Davidson will be retained indefinitely so that we may contact you about other positions that may also be of interest to you.

Accuracy

In order to provide you with a professional level of service and with appropriate benefits, we will endeavor to ensure that the personal information we collect will be as accurate, complete and current as is necessary to fulfill the purposes for which it is to be used. Davidson will not routinely update personal information; however, from time to time, you may be asked to update your personal information. You are encouraged to advise us of any changes to your personal information that may be relevant to the services we are providing to you.

As a client, you are encouraged to contact your engagement partner to update your personal information. As a partner or employee, you are encouraged to contact the Privacy Partner at privacy@Davidson-Co.com should you need to update your personal information.

Safeguards

Davidson will take all commercially reasonable steps to ensure that your personal information in our possession is protected against loss or theft as well as unauthorized access, disclosure, copying, use or modification through security safeguards appropriate to the sensitivity of the information. This protection applies to information stored in both electronic and hard copy form. Personal information collected is stored in secure operating environments that are not available to the public (i.e. restricted access premises, locked rooms, filing cabinets) and access to your personal information will be restricted to selected employees or representatives. In addition, Davidson will employ generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect personal information against loss and unauthorized access.

Openness

Davidson will make readily available to individuals specific information about its policies and practices relating to the management of personal information. All enquiries about this general privacy policy or Davidson's personal information management practices are to be referred to the Privacy Partner at privacy@Davidson-Co.com .

Access

As a client, you have the right to review and obtain a copy of your personal information on record by contacting your engagement partner. As a partner or employee, you also have the right to review and obtain copies of your personal information on record by contacting the Privacy Partner at privacy@Davidson-Co.com . Upon request, Davidson will inform an individual of the existence, use and disclosure of his or her personal information and provide access to that information, except where access is not required by law. Individuals can challenge the accuracy and completeness of personal information controlled by Davidson and may have it amended, if appropriate.

Challenging Compliance

All enquiries about this general privacy policy or the personal information management practices of Davidson should be forwarded to the Privacy Partner at privacy@Davidson-Co.com . We will inform individuals who make inquiries or lodge complaints about our complaint procedures and we will investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.

MODIFICATIONS

Davidson reserves the right to modify or amend this general privacy policy at any time. The last edited date will be displayed at the end of this general privacy policy. Davidson may change this general privacy policy as needed and if changes are made, please note that it may take up to 30 business days before new privacy practices are implemented. Check this page periodically if you would like to monitor changes.

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We recognize our responsibility for protecting the privacy of your personal information and welcome your inquiries or comments about our general privacy policy or your privacy and our role in protecting it. You may direct these to the Privacy Partner at privacy@Davidson-Co.com .

Last updated: March 2007