Privacy Policy

Thompson Dorfman Sweatman LLP – Policy Governing the Collection, Use and Disclosure of Personal Information (the “Privacy Policy”)

The website (the “Site”) is operated by Thompson Dorfman Sweatman LLP and its affiliates, Christianson TDS and Roy Johnston TDS (also referred to as collectively “TDS”, “us”, or “we”).  We respect your right to control your personal information. That is why we have developed this privacy policy (the “Privacy Policy”). The Privacy Policy describes:

  • the types of personal information we collect about you;
  • the purposes for which we collect that information;
  • how we use that information;
  • with whom we share that information;
  • how we safeguard that information;
  • the choices available to you regarding how we use your personal information; and
  • how you can contact us about our privacy practices.

This page contains the Privacy Policy for the Site, as well as for any other websites or microsites operated by TDS (collectively and together with the Site, the “Sites”), and for web applications, mobile applications, tools, forums, chatbots, or social media pages offered by TDS on the Sites, and for any online services offered by TDS, including but not limited to providing information on our lawyers and the fields in which they practice, articles, webinars and videos of interest, and our locations (together with the Sites, the “Service”).

By accessing or using the Service, you consent to the collection, use and disclosure of personal information by TDS in accordance with this Privacy Policy. You may choose not to provide us with personal information.  However, if you make this choice we may not be able to provide you with the application, service or information that you requested.

The manner in which TDS handles your personal information is also governed, in part, by the Law Society of Manitoba Code of Professional Conduct and applicable laws. As legal professionals, we are under an obligation to keep confidential information that our clients disclose in the context of the lawyer-client relationship. TDS is committed to dealing with personal information in a manner consistent with all legal and professional responsibilities and with the principles set out in this Privacy Policy.

We recommend that you read this entire Privacy Policy to ensure that you are fully informed. However, you can access specific sections of this Privacy Policy based on the type of information you are looking for by clicking on the links below.

We recommend that you read this entire Privacy Policy to ensure that you are fully informed. However, you can access specific sections of this Privacy Policy based on the type of information you are looking for by clicking on the links below.

  1. What are the key defined terms used throughout the Privacy Policy?
  2. What personal information do we collect?
  3. What is the purpose of the collection and use of your personal information?
  4. To whom do we disclose your personal information?
  5. What if there is a change in the initial purpose of collection of your personal information?
  6. Do we knowingly collect personal information about children?
  7. How do we safeguard your personal information?
  8. Do we transfer your personal information to third parties located in other jurisdictions for storage or processing?
  9. How long do we retain your personal information?
  10. Do we collect, use, and disclose non-personal information about you?
  11. How do we ensure the accuracy of your personal information?
  12. How can you access your personal information?
  13. What types of “cookies” and/or other technologies do we use and how can you change your “cookie” settings?
  14. Do we have links to other websites on the Service? If so, which Privacy Policy governs?
  15. Do we use third party advertising partners? If so, how can I opt out of targeted advertising?
  16. What type of analytics services do we use and for what purpose? How can you disable analytics?
  17. Who do you contact if you have an inquiry, complaint, or want to request a review of your personal information?
  18. How do we handle complaints?
  19. How do you withdraw your consent to the collection, use or disclosure of your personal information?
  20. How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services?
  21. If changes are made to the Privacy Policy, will you be notified? If so, how will you be notified?
  22. Definitions


  1. What are the key defined terms used throughout the Privacy Policy?

For the purposes of this Privacy Policy, the following words have the following meanings:

collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.

consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by an individual or by an authorized representative, such as a parent or guardian.  Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, electronically or in writing.  Implied consent is the assumption of consent that can reasonably be inferred from a user’s action or inaction.

user” means an individual who uses the Service provided by TDS, including anyone else who accesses or visits the Sites and the Service.

disclosure” means making personal information available to a third party.

employee” means an employee of TDS, and for the purpose of this Privacy Policy only, includes agents, independent and other contractors performing services for TDS.

non-personal information” means information that does not identify a specific individual and which we are unable to connect to other information in order to identify a specific individual.

personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.

third party” means an individual other than the user, or the user’s agent, or an organization other than TDS.

use” means the treatment, handling and management of personal information by and within TDS.

  1. Personal Information We Collect

When you interact with us through the Service, we may collect or receive the following types of information.

Personal Information You Provide To Us

TDS collects personal information for the purpose of providing potential clients and clients with legal services and information. The kinds of information that TDS collects about potential clients and clients depends upon the legal services and information that they have requested. TDS endeavours to collect personal information directly from the individual to whom the information relates. This information may include the following:

(a)             Contact Information (Business and Home): name, company name, birth date, occupation, postal address, telephone number, e-mail address, and fax number;

(b)             Identification: depending upon the nature of the services provided to you, photocopies of valid government-issued identification, such as a driver’s license or birth certificate;

(c)             Information Relating to Your Legal Issue: depending upon the nature of the issue, information about your family and employment status, business affairs, financial affairs, and property ownership;

(d)             Relevant Parties: information about contracting parties, adverse parties, employees, witnesses and other individuals relevant to your legal issue;

(e)             Information Provided by You: information provided by you in the course of your communications with TDS or information that you have expressly given TDS consent to collect; and

(f)               Professional/Legal Obligations: information permitted or required to be collected by law or to meet our professional obligations.

You may provide us with your personal information in different ways. For example, we may collect any or all of the following personal information if the information is reasonably required to provide the Service to you:

(a)             information that you provide to TDS when you use the Online Payment tool, such as your billing address, payment method and credit card information. We use third parties such as Bambora Inc. to process credit card payments made by you and, except for a limited number of clients, discard the credit card information once payment has been processed over the phone;

(b)             your correspondence with TDS employees, including any questions, concerns or comments you may have about the Service or problems that you report;

(c)             comments, videos, photographs, and any other content or information that you may post or submit to the Service; and/or

(d)             details of your requests made through the Service.

Technical Information We Collect Automatically

When you visit the Service, we may collect, using electronic means, technical information. This information may include:

(a)             the IP address of your computer and which browser you used to view our Service;

(b)             operating system;

(c)             resolution of screen;

(d)             location;

(e)             language settings in browsers; and/or

(f)               the site you came from and searched for keywords if arriving from a search engine.

This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Service. We do not attempt to combine this technical information with other personal information we collect on our Service.

Usage of our Service does not constitute legal advice or solicitation and does not create a solicitor-client relationship as such information collected through our Service is not protected by solicitor-client privileges.

  1. Purpose of Collection and Use of Personal Information

TDS collects your personal information and will use your personal information as is reasonably required for the following purposes:

(a)             to determine whether there is a conflict of interest which would prevent us from acting for you;

(b)             to provide the legal services and information that you have requested;

(c)             to report to you about your file and/or respond to your requests or inquiries;

(d)             to provide web applications, the Service, and/or the other services or information that you request;

(e)             to verify your identity if you submit questions, comments, job applications, or complaints to the Service;

(f)               to respond to questions, comments, requests, job applications, or complaints that you submit to TDS, including via chatbots;

(g)             to administer and bill your account;

(h)             to collect amounts owing from you to TDS, if applicable;

(i)               to process payments made by you to TDS;

(j)               to track communications with you;

(k)             to analyze use of the Service and to improve the Service;

(l)               to improve customer service and our products and services;

(m)           to send emails, newsletters, regular mail or other communications, including invitations to legal seminars or other events that may be of interest to you, which you have consented to receive from TDS;

(n)             to provide Service-related announcements or notifications to you;

(o)             to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you;

(p)             to manage and serve our advertising on other sites. See Section 15 on targeted advertising and how you may opt out;

(q)             to fulfill a purpose that we disclose to you when we request your personal information; and/or

(r)              to meet legal, professional, and regulatory requirements.

Your personal information will only be collected and used by TDS and employees, agents,  partners and service providers in a manner consistent with the activities of TDS. Access to your personal information by employees, agents, partners and service providers is limited only to those authorized, based on their need to deal with the personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for TDS.

  1. Disclosure of Personal Information

TDS may disclose your personal information to:

(a)             its employees, agents, partners, and service providers as is reasonably necessary to enable these parties to perform a business, professional or technical support function for TDS;

(b)             a person who, in the reasonable judgment of TDS, is seeking the information as your agent; and

(c)             a third party or parties, where you consent to such disclosure or the disclosure is permitted or required by law.

TDS may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.

Corporate Reorganization and Business Transfers

TDS may also disclose your personal information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

  1. Change of Purpose

TDS will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 21.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

TDS will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 21.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

  1. Children

The Service is intended for general audiences and is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under the age of 13, we will take appropriate steps to delete that personal information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in Section 17.

  1. Safeguarding Your Personal Information

TDS is committed to safeguarding your personal information. TDS uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by TDS include, but are not limited to:

  • administrative safeguards such as privacy and security policies and procedures, privacy and data protection training for TDS staff and agents.
  • technical safeguards such as security testing, vulnerability scans, and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks. For example, we use encryption technology, such as Secure Socket Layers, to secure personal information you submit to us and to prevent such information from being intercepted and read as it is transmitted over the Internet to our servers.
  • physical safeguards such as locked filing cabinets, and need-to-know access for TDS employees.

TDS also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.

TDS takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to that information.

While TDS is committed to safeguarding your personal information, we cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you do so at your own risk.

TDS cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property. 

TDS also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal information communicated to or from TDS via the Internet or regarding the interception by third parties. 

  1. Cross Border Transfer of Personal Information

Your personal information may be stored and processed in any country where we engage third party service providers (e.g. Canada, United States). While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For example, personal information stored in the United States is subject to the US PATRIOT ACT.

Regardless of where your personal information may be stored and processed, TDS’s practices will at all times continue to be governed by this Privacy Policy. In addition, TDS has measures in place to ensure that when your personal information is transferred to a third party for processing, whether within or outside Canada, it is subject to appropriate safeguards in accordance with applicable data protection laws. These measures typically include contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used.

Where and when appropriate, we will transmit amended personal information to third parties having access to the personal information in question.

  1. Retention of Personal Information

TDS will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy Privacy and in order to comply with our legal, professional, and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

  1. Non-Personal Information

We may collect, use and disclose non-personal information, including aggregated data resulting from the combination and/or aggregation or certain raw data collected from you with other data in a way that no longer personally identifies you. We make no attempt to link this non-personal information with the identity of individuals. We may permanently archive non-personal information for future use in any manner whatsoever.

  1. Accuracy of Personal Information

TDS is committed to keeping your personal information as complete, up-to-date and accurate as is necessary for the purposes for which it is to be used. TDS will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, TDS will transmit amended information to third parties having access to the personal information in question.

  1. Access to Personal Information

Upon request, TDS will provide you with a reasonable opportunity to review the accuracy of your personal information. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.

Also upon request, TDS will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, TDS will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.

In certain situations, TDS may not be able to provide access to all of the personal information we hold about you. In such a case, we will provide the reasons for denying access upon request. Such reasons may include:

(a)             if doing so would likely reveal personal information about another individual that cannot be severed or the information could reasonably be expected to threaten the life or security of another individual;

(b)             if doing so would reveal any of our confidential information;

(c)             if the information is protected by solicitor-client privilege;

(d)             if the information was generated in the course of a formal dispute resolution process; or

(e)             if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or that of a foreign jurisdiction.

Individuals can obtain information or seek access to their personal information by contacting our Privacy Officer pursuant to Section 17 of this Privacy Policy during regular business hours.

  1. Cookies and Similar Technologies

The Service uses “cookies”, which are small text files placed on your computer or other device when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

There are three main types of cookies:

(a)             Session Cookies are specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don’t have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

(b)             Persistent Cookies record information about your preferences and are stored in your browser cache or mobile device and remain on your device between browsing sessions. For example, a persistent cookie may be used on a website to remember your log-in details so you will not need to enter those details each time you visit that website; and

Third Party Cookies placed by someone other than us which may gather data across multiple websites or sessions.

We use the below listed cookies to perform the following functions:

(g)             Strictly Necessary / Technical Cookies that are essential to enable you to move around a website and use its features. You cannot withdraw your consent to the use of these types of cookies because without them, the Service cannot be provided.

(h)             Analytical / Performance Cookies that collect information in aggregated form about how users interact with the Service so that we may improve functionality. These cookies are sometimes placed by third party providers which enable features or functionality provided by third parties in connection with the Service. For example, advertising, interactive content, and analytics (see Section 16 below). The parties that set these third-party cookies can recognize your device both when it visits the website in question and also when it visits certain other websites.

(i)               Functional Cookies that allow a website to remember choices you make, recognize you when you return and to personalize content.

(j)               Targeting / Advertising Cookies that track browser habits and used to deliver targeted (interest-based) advertising based on your browsing activities and interests. See Section 15 on how you may opt out of targeting advertising.

You acknowledge that where we allow third parties to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party’s privacy policy for information on what information they collect and how they use it. These cookies are likely to be analytical/performance cookies or targeting cookies.

Other Technologies

We may use other technologies similar to cookies like web beacons, which are sometimes called “tracking pixels” or “clear gifs”. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited the Service or opened an email that we have sent them. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Right to Refuse the Use of Information Collection Technologies

We obtain your consent to our information collection technologies through our opt-in mechanism on our website. You have the right to object to the use of information collection technologies such as cookies. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.

Please be aware that if you disable or remove these technologies you may find that certain functions and features will not work as intended on the Service and that when you revisit our website your ability to limit cookies is subject to your browser settings and limitations.

  1. Links to Other Websites

The Service may contain links to other sites, such as Facebook, Instagram, YouTube, Twitter, and LinkedIn. This Privacy Policy only applies to personal information that we collect, use and disclose. We are not responsible or liable for the privacy practices of third parties, and we strongly recommend that you review their privacy policies before you disclose personal information to them.

  1. Targeted Advertising and How You May Opt Out

We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to manage and serve our advertising on other sites. You have a variety of options to opt out of interest based advertising ranging from browser controls, add on utilities such as ad blockers, and other opt out tools. Opt out tools may include organizations such as:

  1. Analytics

The Service employs Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the Service, compiling reports on the Service’s activity for the Service’s operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.  Google will not associate your IP address with any other information held by Google.

We may also use additional analytics programs from time to time to process non-personal information about you.

We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by TDS.

Disable Google Analytics

You can prevent the collection and processing of cookie created data relating to your utilization of the Service (including your IP) via Google by downloading and installing the browser-plugin available under the following link (

Google currently offers this opt-out tool for Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera.

Further information concerning the terms and conditions of Google’s use and data privacy can be found at or at

  1. Contact Us

To submit an inquiry, complaint, request a review of your personal information, correct or update your personal information, withdraw your consent or request more information or additional copies of this Privacy Policy contact:

Privacy Policy Administrator

Mailing Address: 

Thompson Dorfman Sweatman LLP
1700-242 Hargrave Street
Winnipeg, Manitoba R3C 0V1

Telephone No.:  (204) 957-1930

  1. Complaints

TDS will promptly investigate all complaints concerning our compliance with this Privacy Policy and our dealings with your personal information.  If a complaint is found to be justified, TDS will take appropriate measures to resolve the complaint, including, if necessary, amending our policies and procedures. You will be informed of the outcome of the investigation regarding your complaint.

  1. Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information by TDS at any time, subject to legal or contractual restrictions and reasonable notice.  In certain circumstances, your withdrawal of consent may result in the inability of TDS to continue providing certain legal services to you. Please contact TDS for more information regarding the implications of withdrawing consent.

  1. Unsubscribe from Commercial Electronic Messages

If a user decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related service information for example. If at any time the user would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email. Please note that, after you unsubscribe, TDS may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that TDS is legally obligated to provide you.

  1. Privacy Policy Changes

We may modify this Privacy Policy to accommodate changes in our services, changes in technology and legal developments. If we make changes to this Privacy Policy, we will provide notice through the Service, or by other means to provide you the opportunity to review the changes before they become effective. For example, we may place a prominent notice on the Service or e-mail you to let you know of an updated Privacy Policy.

If we make significant changes to the Privacy Policy, we will provide at least 30 days’ notice through the Service, or by other means, to provide you the opportunity to review the changes and provide your required consent before they become effective. A significant change may be using personal information for a new purpose or disclosures to new third parties.

You acknowledge that your continued use of the Service after we modify this Privacy Policy, publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you object to any changes to this Privacy Policy you may close your account.

Whenever we update this Privacy Policy, we will change the date below to indicate when the changes were made.

Date: February 19, 2021