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Frasca Kim Personal Injury and Insurance Lawyers (‘FRASCA KIM Lawyers’) is a law firm with offices in Thunder Bay, Ontario. Consistent with our obligations as professionals, we are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. This Privacy Policy has been prepared to affirm our commitment to maintaining the privacy of our clients and others and to inform you of our practices concerning the collection, use and disclosure of Personal Information (as defined below) collected by FRASCA KIM Lawyers. This Privacy Policy not only applies to FRASCA KIM Lawyers but also FRASCA KIM Lawyers International Inc., FRASCA KIM Lawyers Consulting Inc., FRASCA KIM Lawyers Canada Inc. and associated management and consulting companies.

Our obligations as legal professionals are governed, in part, by the Rules of Professional Conduct that govern each of our professionals as members of Law Societies. These obligations apply to all professionals, employees, contractors and agents who provide services in connection with our delivery of legal and other services to our clients. Other applicable laws and internal Firm policies govern the protection of Personal Information of partners, associates and employees of FRASCA KIM Lawyers.

For the purposes of this Privacy Policy, “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. This Privacy Policy does not cover any information, recorded in any form, about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”). FRASCA KIM Lawyers retains the right to use Aggregated Information in any way that it reasonably determines is appropriate.

Using contractual or other arrangements, FRASCA KIM Lawyers shall ensure that agents, contractors and third party service providers, who may receive Personal Information in the course of providing services to KIM Lawyers as part of our delivery of products and services, protect that Personal Information in a manner consistent with the principles articulated in this Privacy Policy and applicable laws.


As a general rule, all information concerning the business and affairs of a person or organization acquired (1) for the purpose of determining whether FRASCA KIM Lawyers will enter into a professional relationship or (2) in the course of a professional relationship shall be held in strict confidence and not revealed to anyone unless expressly or implicitly authorized by the person or organization concerned. A professional relationship develops when FRASCA KIM Lawyers agrees to be retained to provide services to a particular individual or organization. In order to protect their own interests, individuals or organizations should not send confidential information to FRASCA KIM Lawyers until they have had a direct discussion with a professional at the firm regarding the retention of FRASCA KIM Lawyers to provide legal services.


Your provision of Personal Information to FRASCA KIM Lawyers means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy. If you do not agree with these terms, you are requested not to provide any Personal Information to FRASCA KIM Lawyers. Unfortunately, certain services can only be offered if you provide Personal Information to FRASCA KIM Lawyers. Consequently, if you choose not provide us with any required Personal Information, FRASCA KIM Lawyers may not be able to offer you those services.

FRASCA KIM Lawyers collects only such information from individuals or organizations as is required for the purposes of providing services or information to them. FRASCA KIM Lawyers collects e-mail and mailing addresses in connection with the provision of such services and information, including preparing retainer letters, complying with “know your client” rules, opening new files/matters, allowing individuals to access and use virtual data rooms or subscribe to a publication offered by the Firm. The Firm uses information collected through such subscriptions to send subscribers the publication they have requested, and to provide information that may be of possible interest.

FRASCA KIM Lawyers does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no Personal Information is collected about an individual, without first obtaining the consent of the individual to the collection, use and dissemination of that information.

Personal Information will be collected, to the extent possible, directly from the individual concerned.

Unless in the context of providing legal or other services, FRASCA KIM Lawyers does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if it discovers that it is has been provided by a minor.

FRASCA KIM Lawyers may disclose Personal Information to organizations that perform services on behalf of the Firm. Personal Information will only be provided to such organizations if they agree to use such information solely for the purposes of providing services to FRASCA KIM Lawyers and under the instruction of FRASCA KIM Lawyers and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

Personal Information may also be subject to transfer to another organization in the event of a merger or change of ownership of all or part of FRASCA KIM Lawyers. This will occur only if the parties have entered into an agreement under which the collection, use and disclosure of the information is restricted to those purposes that relate to the business transaction, including a determination whether or not to proceed with the business transaction, and is to be used by the parties to carry out and complete the business transaction.

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where KIM Lawyers is obliged to disclose information without consent. Such circumstances may include:

  • Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
  • Where FRASCA KIM Lawyers believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
  • Where it is necessary to establish or collect monies owing to FRASCA KIM Lawyers;
  • Where it is necessary to permit FRASCA KIM Lawyers to pursue available remedies or limit any damages that FRASCA KIM Lawyers may sustain;
  • or Where the information is public. Where obliged or permitted to disclose information without consent, FRASCA KIM Lawyers will not disclose more information than is required.


FRASCA KIM Lawyers endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which FRASCA KIM Lawyers uses that information.


FRASCA KIM Lawyers keeps Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for FRASCA KIM Lawyers’ purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.

Currently, the principal places in which FRASCA KIM Lawyers holds Personal Information are in the cities in which FRASCA KIM Lawyers has offices or production facilities and nearby municipalities where off-site storage facilities may be located. FRASCA KIM Lawyers does allow certain authorized third party providers to track and store certain information about visitors to FRASCA KIM Lawyers web sites (namely domain names, IP addresses and page views as described below) and such information will be stored outside of Canada if the third party provider is located outside of Canada. Individuals that use and access FRASCA KIM Lawyers web sites hereby acknowledge and agree that such information obtained by such third party providers located in countries other than Canada may be accessed by the courts, law enforcement or national security authorities of such country.


FRASCA KIM Lawyers has taken steps to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.

FRASCA KIM Lawyers further protects Personal Information by restricting access to it to those individuals that the management of FRASCA KIM Lawyers has determined need to know that information in order that FRASCA KIM Lawyers may provide its services.

In terms of communicating Personal Information to FRASCA KIM Lawyers, you may wish to note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted.

As do many organizations, FRASCA KIM Lawyers attempts to strike a reasonable balance between security and convenience. In communicating with clients and others, FRASCA KIM Lawyers often requests the right to use a method of communication that is less secure than some of its less convenient alternatives. An example of this is e-mail. At this time, when we use e-mail, it may be sent as unencrypted plain text. We do this because FRASCA KIM Lawyers believes that many of our clients and others cannot readily process encrypted e-mail. This is done for their convenience but we expect that our clients and others understand that if misrouted or intercepted, unencrypted email could be read more easily than encrypted e-mail.


FRASCA KIM Lawyers provides clients and others with general access to public web sites and restricted access to extranets. Our Web servers and authorized third party providers track general information about visitors such as their domain name, IP address and time of visit. FRASCA KIM Lawyers’ Web servers also collect and aggregate information regarding which pages are being accessed as well as information volunteered by visitors through online surveys or subscriptions to electronic newsletters. This information is used internally, only in aggregate form, to better serve visitors by helping us to:

  • Manage our sites
  • Diagnose any technical problems
  • Improve the content of our Web site
  • During the course of an individual’s use of the Internet, he or she will learn of the common use of “cookies.” “Cookies” are files or pieces of information that may be stored in a computer’s hard drive when an individual visits a web site. Most Internet browsers are initially set to accept cookies. If you do not wish to accept cookies, you can set yours to refuse cookies or to alert you when cookies are being sent.


This Privacy Policy is in effect as of January 1, 2013. FRASCA KIM Lawyers will from time to time review and revise its privacy practices and this Privacy Policy. In the event of any amendment, an appropriate notice will be posted on FRASCA KIM Lawyers web site. Policy changes will apply to the information collected from the date of posting of the revised Privacy Policy to FRASCA KIM Lawyers’ web site as well as to existing information held by KIM Lawyers.


In the event an individual has questions about (a) access to Personal Information; (b) the collection, use, management or disclosure of Personal Information; or (c) this Privacy Policy, that individual should contact the Firm’s Chief Privacy Officer.