Your Privacy Rights
On January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act. The Act gives all Canadians rights concerning the privacy of their personal information.

The Millar Corporation is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy. The Millar Corporation's Chief Privacy Officer ensures that proper personal information procedures and policies are in place, and that all company consultants and employees abide by the procedures that are established to protect our clients' personal information.

Why Does The Millar Corporation Need Personal Information?
The consultants and other staff members at The Millar Corporation must collect personal information from our clients to fully understand and address their family business succession/estate planning, insurance and/or wealth management requirements and to provide them with the appropriate services needed to achieve their objectives. Personal information is collected during the initial client contact as well as on an ongoing basis as we work with our clients throughout the planning and implementation process. In most cases, the personal information is collected directly from our clients. However, at times, we may obtain personal information about our clients from other sources that is required to deliver our services, with our clients' permission: for example, from lawyers, accountants, physicians, insurance companies or other financial institutions that work with our clients. All of this information is treated with the same standard of care.

The Use Of Your Personal Information
We limit our collection of personal information to what is required to provide estate planning, insurance or investment management services for you and future updates of these arrangements. If you tell us that you no longer wish to receive our services or updates, we will not send any further information to you. We do not sell, trade or exchange any personal information that we receive from our clients with third parties to market their products.

Disclosure Of Your Personal Information
Any personal information we receive is held in strict confidence. However, we may need to disclose personal information to provide you with the services you have requested, or if we are required to do so by law. Circumstances that may require disclosure include:

	When we are required or authorized by law to do so, for example if a court issues a subpoena.
	When you have consented to the disclosure.
	When the services we are providing to you require us to give your information to third parties (for example, to an insurance company underwriting life insurance coverage or to an investment dealer to transact investment business). In these situations, your consent will be implied, unless you tell us otherwise.
	Where it is necessary to establish or collect fees.
	If we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage) and the third party is bound by our privacy policy.
	If the information is already publicly known.

Updating Information And Correcting Errors
Since we use our clients' contact and other personal information to provide services to them, it is important that the information be accurate and current. Therefore, we ask our clients to inform us of any change in their personal information so that we can update our files and records. When a client advises us that the personal information we hold is not accurate, complete or current, The Millar Corporation will take all reasonable steps to correct it.

Is My Personal Information Secure?
The Millar Corporation endeavors to take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Safeguards in place to protect your personal information include premise security, restricted file access, proper destruction procedures and technological safeguards like security software, firewalls, internal password procedures and security policies.

Access To Your Personal Information
You may ask for access to your personal information that we hold at any time. Requests that require archive or other retrieval costs (i.e., from insurance or investment institutions) may be subject to professional or disbursement fees. The Millar Corporation, in limited circumstances, may deny access when:

· denial of access if required or authorized by law (for example, when a record containing personal information about the requester is subject to a claim of legal professional privilege by one of our other clients);

	information relates to existing or anticipated legal proceedings against a client;
	granting access to a client would have an unreasonable impact on other people's privacy;
	to do so would prejudice negotiations with a client; · protecting The Millar Corporation's rights and property; or
	the request is frivolous or vexatious.

If we refuse your request for access, or refuse a request to correct information, we will send a letter to you outlining why your request has been denied.

Requests For Access Or Other Privacy Questions Or Concerns

If you have any questions about The Millar Corporation's personal information practices, or if you wish to request access to the personal information we hold, or wish to file a complaint, please write to our Chief Privacy Officer:

Chief Privacy Officer
The Millar Corporation
30 Concourse Gate, Suite 209
Nepean, Ontario
K2E 7V7

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Ottawa, Ontario
K1A 1H3
1-800-282-1376

Note I - The Client Privacy Policy for The Millar Corporation (which is described in this document), also applies to the affiliated companies of The Millar Corporation: The Millar & Associates Insurance Agency (Ottawa) Limited (Millar & Associates) and Millar Wealth Management Inc., which are the corporate entities used for the processing and administration of insurance and/or investment transactions for our clients.

Note II - Millar & Associates has contracts with the following insurance companies: AIG, Canada Life, Empire Life, Equitable Life, Great-West Life, Manulife Financial, Maritime Life, RBC Life, Standard Life, Sun Life and Transamerica.