Privacy policy and cookie policy

Armotrain Inc. takes your and our privacy very seriously. To that end, we will take reasonable measures within our control to ensure the security of your information and your time spent on our website. As always, we welcome your feedback.

Armotrain Inc. and our respective subsidiaries, parent companies, and affiliates (the “Company,” “we,” “our,” or “us”) value your privacy and care about how your personal information is handled.

This Privacy Policy (“Policy”) describes the personal information we may collect, use, disclose, and otherwise process about individuals, as well as our practices for processing personal information. This Policy applies to our website armotrain.ca, as well as the websites of our affiliated companies Armoroofing and Armosteel at armoroofing.ca and armosteel.ca (the “Sites”). It also applies to:

• current, former, and prospective business partners, vendors and service providers;

• individuals who register for or participate in our events, surveys, research, and promotions;

• individuals who subscribe to receive news, information, and marketing communications and ‎materials from us; ‎and

• individuals who communicate or otherwise interact or engage with us through our Sites.‎

Other Notices. Depending on how you interact or engage with us, we may provide you with ‎other privacy notices with additional details about our privacy practices. These additional notices ‎will control to the extent that there is a conflict with this Policy. For example, this Policy does not ‎apply to the personal information that we collect and process about job applicants and ‎candidates for employment with us, or to employees or contractors in the context of our working ‎relationship with them.‎

By providing personal information to us, you agree to the processing set out in this Policy as well as authorize the Company, its third parties and service providers to process your personal information for the purposes set out below.

I. COLLECTION OF PERSONAL INFORMATION

For the purposes of this Policy, “personal information” is information about an identifiable individual whether identified directly or indirectly. For the purposes of this Policy, personal information does not include information normally used to contact an individual at their place of business except as required by applicable privacy and data protection law.

Personal Information Collected Directly from You. While the personal information we collect ‎varies depending upon your use of our Sites and our interactions with you. In general, we may ‎collect the following personal information directly from you:‎

• Information that is reasonably required to conduct business with the Company or for the Company’s operations. Depending on the nature of your business relationship with us, this may include, but is not limited to: name, contact information (e.g. email address, phone number(s), address, or other similar identifiers), preferred means of communication, photograph, employer and job title (if working on behalf of one of our service providers), as well as your message, the nature of your inquiry, and any ‎other information you so choose to provide.

• Communications and Interactions. When you email, call, or otherwise communicate or ‎interact with us, including if you sign up for our mailing lists, complete forms on our Sites, ‎interact with our social media pages, post a product review or testimonial, submit content ‎in any online discussion groups, or otherwise enter information into public-facing ‎comment fields, blogs, or community forums sponsored by or affiliated with the Company or its affiliates, we ‎may collect and maintain records of your contact details, communications and ‎interactions, and your posts or submissions.‎

• Promotional and Marketing Information. If you agree to receive marketing communications from us, we ‎may collect your name, email address, phone number, preferences, and if relevant, ‎information about your account and profile, including the Sites and features you use. If ‎you participate in special activities, offers, programs, or promotions we ‎offer, we may also collect certain contact details, your age, and any other information ‎that may be required by law.

• Preferences and Other Requests. We may also collect information about your ‎preferences, including communications preferences, preferences related to your use of ‎our Sites, and any other preferences or requests you provide when interacting with us.‎

• Business Development and Operations Information. To assess and pursue potential ‎business opportunities, and to operate our business, we may collect and receive personal ‎information about current, former, and prospective business partners, and vendors and ‎service providers, including contact information, where applicable privacy law considers such contact information to be personal information.‎

Personal Information Collected Through Our Sites:

• Website activity and usage information. When you visit our Sites and when you communicate with us, we may collect a certain amount of personal information about you. Specifically, the Company may collect the following information regarding visitors to our Sites: domain name, information regarding your interaction with the Company’s websites, social media sites and mobile applications (including content viewed or downloaded, features used, links clicked, etc.). Like most websites and other Internet services, we may collect certain technical and device information about your use of the website, including but not limited to information concerning the type of device, internet browser, language or computer operating system you are using, your IP address, your location, the domain name of your internet service provider, access times, referring website information, and other information you provide to us. To the extent required by applicable law, we will obtain your consent before collecting ‎such information from you.‎

Links to Other Sites

Our Services may contain links to third-party software, websites, applications or Internet resources ‎‎(“Third-Party Services”) that are provided solely for your convenience and information. When you click ‎on one of those links you are contacting those Third-Party Services. We do not endorse, and have no ‎responsibility or liability for, or control over, those Third-Party Services or their processing of your ‎personal information. We encourage you to read their privacy policies to learn how they process your ‎personal information. ‎

Cookies and Tracking

To the extent permitted by applicable law and, where required, with your consent,‎ the Company may use cookies and other tracking technologies to collect browsing, activity, device and similar information within our Sites.

A “cookie” is a unique identifier which is used by us to customize the Company’s websites, mobile application or social media site experience. Cookies can enhance your user experience by, for example, saving your preferences and personalizing your online experience. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to support the security and performance of the Sites, or allow us to track aggregate and statistical information about user activity within the Sites.

The Company also uses the information collected in cookies for the purposes of helping to improve its social media sites and services.

Most web browsers automatically accept cookies, but you can usually change your browser to prevent or notify you whenever you are sent a cookie. This gives you the opportunity to decide whether or not to accept the cookie. Although you are not required to accept cookies when you visit our websites, you may be unable to use all of the functionality of the site if you reject certain cookies.

In addition, if you delete or block cookies, you may need to reapply these preferences ‎to each browser and/or device.

• Cookie Settings. To prevent cookies from tracking your activity on our Sites or visits across ‎multiple websites, you can set your browser to block certain cookies or notify you when a ‎cookie is set. You can also delete cookies. The “Help” portion of the toolbar on most ‎browsers will tell you how to prevent your device from accepting new cookies, how to ‎have the browser notify you when you receive a new cookie, or how to delete cookies. ‎Visitors to our Sites who disable cookies will be able to browse the Sites, but some ‎features may not function.‎

• Tracking and profiling technologies. Notwithstanding any provision to the contrary in ‎this Policy, we ‎will only collect your personal information using technology which allows ‎you to be located, profiled or ‎tracked (i) after having duly informed you of our intent to ‎use such technologies and (ii) if you choose ‎to activate such technologies.‎

Third Party Analytics. To the extent permitted by applicable law and, where required, with your consent,‎ the Company may use automated devices, applications, and tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Sites. These third-party companies may use cookies, pixels, and other tracking technologies to collect usage data about our Sites and provide us with reports and metrics that help us evaluate usage of our Sites and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-Party Advertising. The Company works with third-party ad networks, analytics, marketing partners, and others such as Google Ads (“third-party ad companies”) to personalize content and display advertising within our Sites, as well as to manage our advertising on third-party sites. To the extent permitted by applicable law and, where required, with your consent, we and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Sites (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Sites and on third-party sites, and to evaluate the success of such ads and content. When you visit our website, our third-party ad companies may also use your personal information for their own business purposes, including for the third-party ad-company’s s marketing programs.

Cross-Device Use. To the extent permitted by applicable law and, where required, with your consent,‎ the Company and our third-party service providers may use the information we collect about you (whether directly from our Sites, through your device(s), or from third party sources) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers may also use the information we learn about you to serve targeted advertising or personalize content within our Sites. To opt-out of cross-device advertising, you may follow the instructions set forth below. Please note, if you opt-out of these targeted advertising cookies, the opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

II. PURPOSE AND LEGAL BASIS FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

The Company may collect, use and disclose your personal information for the following non-limited purposes:

• to administer the Company’s provision of, and your payment for, products or services that you request from the Company;

• to authenticate your identity;

• to operate, customize and improve the quality of the Sites, social media sites, mobile applications, advertisements, products and services;

• to tailor content we may send to you or display on the Sites, including to offer location customization and ‎to otherwise personalize your experiences and offerings;

• to monitor your compliance with any of your agreements with the Company, including your use of the Sites;

• to provide newsletters, electronic messages and information you request from the Company;

• to provide other information to you regarding the Company’s products and services or third party products and services, unless you opt out of receiving that information;

• to assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other ‎business transactions such as financings, and to operate our business and administer our ‎business, accounting, auditing, compliance, recordkeeping, and legal functions;

• to conduct financial, tax and accounting audits, and assessments of our ‎operations, including our privacy, security, and financial controls, as well as for risk and ‎compliance purposes. We may also use personal information to maintain appropriate ‎business records and enforce our policies and procedures.‎

• to protect the Company, yourself and others from fraud and error and to safeguard the Company’s business interests;

• to collect debts owed to the Company;

• to obtain legal, accounting or other professional advisory advice;

• otherwise with your consent or as required or authorized by applicable law.

To fulfill the above purposes, the Company may disclose personal information about individuals on a selective basis to third parties as required or permitted by law or as consented to from time to time by the individual. The organizations to which the Company may disclose personal information include, but are not limited to:

• government agencies;

• insurance companies;

• banks and other financial institutions;

• professionals advising or working on behalf of the Company such as lawyers, actuaries and benefit consultants;

• vendors and service providers to the Company, such as IT and website hosting, product shipment and order fulfillment facilitators, marketing and ‎marketing research providers, customer support, data storage, data analytics providers, ‎auditors, consultants, and legal counsel‎; and

• affiliates and business associates of the Company, as reasonably required in connection with the operations of the Company.

We may also disclose your personal information in the following circumstances:‎

• In Support of Business Transfers. If we are or may be acquired by, ‎merged with, or invested in by another company, or if any of our assets are or may be ‎transferred to another company, whether as part of a bankruptcy or insolvency ‎proceeding or otherwise, we may disclose or transfer the personal information we have ‎collected from you with or to the other company in accordance with applicable laws. We ‎may also disclose certain personal information as necessary prior to the completion of ‎such a transaction or other corporate transaction such as a financing or restructuring, to ‎lenders, auditors, and third-party advisors, including attorneys and consultants;

• To Meet Compliance and Legal Obligations. We may also disclose personal information to third ‎parties to the extent required by applicable law and legal obligations. For example, we ‎may disclose information in response to subpoenas, court orders, and other lawful ‎requests by regulators, government entities, and law enforcement, or as otherwise required ‎by law or legal process. In addition, we may disclose the names of sweepstakes and ‎contests winners in accordance with applicable law;

• Security and Protection of Rights. Where we believe doing so is necessary to protect ‎the Sites, our rights and property, or the rights, property, and safety of others. For ‎example, we may disclose personal information to (i) prevent, detect, investigate, and ‎respond to fraud, unauthorized activities and access, illegal activities, and misuse of the ‎Sites, (ii) situations involving potential threats to the health, safety, or legal rights of any ‎person or third party, or (iii) enforce, detect, investigate, and take action in response to ‎violations of our Terms of Use. We may also disclose personal information related to ‎litigation and other legal claims or proceedings in which we are involved, as well as for ‎our internal accounting, auditing, compliance, recordkeeping, and legal functions.‎

• Other Disclosures. We may disclose personal information in other ways not described ‎above that we notify you of or that we obtain your consent for, or that are otherwise ‎authorized or required by law.‎

CROSS-BORDER TRANSFERS

The Company may transfer your personal information outside of your jurisdiction of residence to fulfill any of the above purposes, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions in accordance with applicable law. We will comply with all applicable laws when making such transfers.

III. RETENTION

The Company retains your personal information for the period of time required to meet the purposes identified in this policy, except as required or authorized by applicable law, after which time your personal information is securely destroyed.

IV. SECURITY

We have implemented reasonable precautions aimed to protect the information we collect from ‎loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware ‎that despite our best efforts, no data security measures can guarantee security.‎

Personal information is retained and destroyed by the Company in accordance with the applicable laws and its document and data retention practices.

The Sites are not intended for individuals under the age of 16. We do not knowingly collect personal information from individuals under the age of 16. If we become aware that we have collected personal information from an individual under the age of 16 without appropriate consent, we will take reasonable steps to delete such information.

V. YOUR PERSONAL INFORMATION RIGHTS

ACCURACY

The Company is required to take reasonable steps to ensure that your personal information in our possession is accurate and complete. You may request that the Company correct an error or omission in your personal information that is under our control. If you request a correction to your personal information and the Company is satisfied on reasonable grounds that there is an error or omission in your personal information, the Company will correct the personal information as soon as reasonably possible and, if applicable, send the corrected personal information to each third party to whom the personal information was disclosed. If we do not correct the information, we will annotate it to show that the request was made

CONSENT

You have the right to withdraw consent to collect your personal information at any time, subject to limits in applicable law.

REQUESTS FOR ACCESS OR CORRECTION

You may have a right to access to or request correction of your personal information ‎held by us. ‎These rights are not absolute but subject to limits in applicable law.‎

Where a request to access your personal information is refused, we will notify you in writing, ‎document the reasons for refusal ‎and outline further steps which are available to you.‎ If a ‎request for correction of your personal information is refused, we will annotate our records to ‎show that the correction was requested but not made.

Quebec ‎residents have the ‎right ‎‎to: ‎

Request, in certain circumstances, that we cease disseminating your personal ‎information or to de-‎index any hyperlink that allows access to that personal ‎information by technological means, if ‎such dissemination contravenes applicable ‎law or a court; and ‎

Request that a copy of your personal information that we hold be communicated to ‎you in a ‎structured, commonly used ‎‎technological format, and that this information ‎be communicated ‎to any person or organization authorized by law to collect such ‎information.‎

MARKETING COMMUNICATIONS

You may opt-out of marketing communications at any time by following the instructions provided to you in the communication. If you opt-out of marketing communications we may still send you communications about your products and services that you have received from us.

VI. UNITED STATES SUPPLEMENT

GENERALLY

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Right to Know. Confirm whether we process their personal information.

• Right to Access and Delete. Access and delete certain personal information.

• Right to Correct. Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).

• Right to Deletion. Request the deletion of your personal information that has been collected, subject to certain exceptions.

• Right to Data Portability. Obtain your personal information in a portable, and to the extent technically feasible, easily usable format that can be transmitted to another entity.

• Right to Opt-Out. Opt-out of personal data processing for:

o targeted advertising (excluding Iowa);

o sales; or

o profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).

• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please reach out to the Privacy Officer at mailto: info@armotrain.ca.

The California-specific supplement is included below in this Policy.

CALIFORNIA: Additional California privacy terms and rights

The state of California enacted the California Consumer Privacy Act in 2018 and amended it in 2020 under the California Privacy Rights Act (hereinafter referred to collectively as “CCPA”). Together, the acts afford certain rights to California residents (hereinafter referred to as “Consumers”). This section specifically addresses the rights of California residents under the CCPA.

A. Collection categories

As explained above in this Policy, we collect a variety of categories of information, including personal information, in connection with providing the services. In this section, we explain these categories again specifically in the context of the CCPA. In providing the services on the Sites, we collect the following categories of personal information: the person’s name, postal/mailing address, IP address, unique personal identifier or online identifier, email address or telephone number, and other data.

B. Information sources

As explained above, we collect personal information from consumers themselves directly via our Sites, through interactions with our company’s personnel, and through social media, and, in some cases, from service providers.

C. Personal information use and sharing for business purposes

As explained in greater detail above, we use the personal information that is collected for a wide variety of business purposes:

• To fulfill any contractual obligations with you related to the Sites;

• To facilitate the establishment and use of accounts created on the Sites;

• To verify your identity and manage access to your accounts on the Sites;

• For analytics purposes and to operate, maintain, and improve the Sites;

• To market the Sites and gather additional information regarding the Sites;

• To create new products and services on the Sites;

• To protect against, investigate, and deter fraudulent, unauthorized, and/or illegal activity on or relating to the Sites; or

• When necessary, to meet legal requirements, such as legally mandated reporting, subpoenas, court orders, or other legal process requirements

D. Sale of personal information

We do not engage in any sale of a consumer’s personal information as that term is defined under the CCPA.

E. Sharing of personal information

The CCPA defines “sharing” as “renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” personal information. We share your personal information, as described above, with the companies that provide cookies and similar technologies used on our Sites. Those companies have access to and might use the personal information gathered through these technologies, which might include an individual consumer’s IP address. Such uses might include targeted advertising information based on individual internet activity and interests. It is possible that some of the businesses providing marketing services to us might share personal information with their business partners. In addition, some companies that provide services to us might need to access and use customer information as part of providing services to us, and these same companies might use this information for the development of their own business capabilities, not solely for the provision of services to us.

To notify us of your desire to restrict the use of your personal information by third parties, contact us and submit your request by emailing us at info@armotrain.ca with the following in the subject line:

“DO NOT SHARE MY PERSONAL INFORMATION”

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Any updates will be posted on this page with a revised “Last updated” date. Continued use of the Sites after such changes constitutes acceptance of the updated Policy, to the extent permitted by applicable law.

If you have any questions about submitting your request, please contact us and submit your request by emailing us at info@armotrain.ca.

F. Your California rights and choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

I. Access to specific information.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the section “Exercising consumer rights” below),