Privacy

Almita Piling Inc. (“Almita”) is an Alberta company which manufactures screw piles and anchors. This Privacy Policy sets out the principles and practices which we will use in protecting personal information that you provide to us.

TYPES OF PERSONAL INFORMATION THAT WE COLLECT We may collect personal information from you or about you either directly or through authorized third parties in person, over the telephone, in written documents, on the Internet, or through warranty registrations, surveys, contests, test drives or other promotions or incentive programs. The types of information that we may collect include, but are not limited to, the following:

information to permit us to identify and contact you such as your name, address, telephone number, e-mail address and language preference; demographic and marketing information about you such as your age, education, occupation, marital and family status, information on your preferences, interests, past purchasing behaviors and practices, prospective purchasing intentions and your experience with competitor products and services; product ownership information; product warranty and servicing information such as warranty or service notifications and service plans; product performance and customer satisfaction information such as product surveys and your experience in purchasing, leasing or servicing our products; and financial and credit information. MEANING OF “PERSONAL INFORMATION” Personal information in this policy means information about an identifiable individual as that term is defined in applicable Canadian federal, provincial or territorial privacy legislation in effect from time to time. As a general rule, Canadian privacy legislation does not consider personal information which is business-related information – such as the information which is shown on a person’s business card – to be personal information. Likewise, non-identifiable personal information – which means information about an individual where the personal identifiers have been removed, so that it is impossible to determine the identity of the person to whom the information relates – is not considered to be personal information.

GIVING CONSENT The collection and use of personal information normally requires the consent of the person giving the information. The personal information collected from users of, and subscribers to, the various sites comprising the Almita network of sites, and the manner in which that information is used, may vary slightly from site to site depending on the nature of the site and the chosen level of involvement of the user. Nevertheless, Almita users shall receive the same level of respect for user privacy that is applied uniformly across the Almita network. However, consent requirements vary depending upon the circumstances in which personal information is collected and the purposes that it will be used for. In many instances written consent is not required and may be implied where it is reasonable to do so. Similarly, there may be situations where consent will be legally deemed to have been given. From time to time, we may collect or use your personal information for purposes not specified in this Privacy Policy, in which case we will obtain your written consent, if legally required.

When you provide personal information to us, you agree that we may collect and use the information that you have provided in accordance with this Privacy Policy. You also represent, in the case of personal information of any other individual that is provided by you to us, that you have the authorization and consent of that individual to permit us to collect and use that individual’s personal information in accordance with this Privacy Policy. Almita may release personal information if required by law, to enforce Almita’s terms of service, or to protect the rights, property or safety of Almita, its registered users, or others. Almita may disclose customer’s personal information to third parties for the distribution of related marketing materials unless otherwise stated.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information in various ways:

From You : For example, when you purchase or lease one of our products, participate in a contest or survey, respond to an offer or program, when you contact us or when you use the interactive portions of our website. From Our Contractors : We collect and use personal information, with your consent, from business organizations that we may contract with from time to time, for example, in connection with marketing and promotional activities, conducting customer surveys, etc. From Our Website : We do not collect personally identifiable information on our website unless you knowingly provide it to us, for example, when you use our website to send us an e-mail message, request a brochure, etc. Our website makes use of cookies to collect information such as the type of browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique alphanumeric identification number that identifies the visitor’s browser, but does not capture any personally-identifiable information. Our website automatically collects non-identifiable personal information on an aggregated basis. For example, we may track the total number of visitors to our website during a 24-hour period, but this information does not allow us to personally identify individual visitors. If you do not agree with our Privacy Policy, please do not provide us with any personal information though our website.

HOW WE USE YOUR PERSONAL INFORMATION We use your personal information to:

identify and communicate with you; provide you with marketing, product, service and incentive offers and information from ourselves, and our business partners. Personal information may be used so that marketing materials can be supplied via ground mail or e-mail to keep consumers aware of the latest introductions and news on any such products and services; conduct market surveys, research and analysis; manage our relationship with you including assisting in the administration or communication to you of information relating to our products, service notifications, warranty servicing, and customer service and product satisfaction matters. Almita may also maintain information about purchasers of other manufacturers’ products to ensure they can be contacted for the same reason; comply with safety, security, legal and regulatory requirements; and protect our reasonable and legitimate business interests. As a Almita member, you will, from time to time, be able to enter contests within the network, sign up to receive or send electronic newsletters, press releases, greetings and other emails or content (such as weekly specials). We use your contact information to send you valuable updates and timely notices of promotions and status reports if you choose to have them sent to you. Our site provides you with the opportunity to opt-out of receiving different types of communications from us at any point. We do not require users to disclose more information than is reasonably necessary to participate in an activity as a condition of participation. We use the information collected to distribute the requested newsletter or other content, to notify contest winners, to enable password protected access to certain services and sections within sites on the network, and to provide whatever other service the user has authorized in providing the contact information.

Some Almita network sites offer users the opportunity to download different manuals and information. To complete such a transaction, users are asked to provide their name, email address, mailing address, telephone number. Once entered, this information is usually saved by the e-commerce site. When you choose to log-on in the future to the network e-commerce site, for your convenience this information may automatically appears in the appropriate spaces (i.e. the information fields are “pre-populated”) on the web page within the site for placing orders.

DISCLOSURE OF YOUR PERSONAL INFORMATION We only disclose your personal information to fulfill the purposes that it was collected for or to satisfy legal requirements, and Almita may share user information with its advertising, affiliates and business partners. As well, this may include the following:

we may provide your personal information to authorized third party contractors who perform functions on our behalf, such as conducting market research, performing product satisfaction surveys, contests, dealer performance surveys, etc. We require all of our contractors who have access to your personal information to keep the information confidential and to restrict its use to those purposes for which we have engaged them; our records of your personal information may be periodically updated by our third party contractors or by our own communications with you. This updated personal information may be shared by us with our affiliates; and as we continue to develop our business, we may at some future date become involved in a transaction in which one of our business units may be acquired or considered for acquisition by a third party. In such circumstances, your personal information would be transferred and/or could be the subject of due diligence investigations by the third party. You agree that Almita and its successors may do so without your further express consent, and you agree that the successor may continue to possess and use the information conveyed in accordance with the terms of this policy. If as a result of the business transition, your personal information will be used in a manner different from that stated at the time of collection members will be given choice consistent with our changes section below. Unless specified otherwise, your provision of information will provide authorization for the usage and provision of that information (along with the other public information): (i) to third parties to allow them to contact you for other marketing or commercial purposes; and (ii) for the use of Almita, our agents, or other third party organizations for other marketing or commercial purposes. If you do not want us to contact you regarding third party products or services or share or continue sharing your information, contact or public information with other companies or organizations, you can do so by changing your privacy preferences.

In all cases, and regardless of any opt outs or otherwise, it is expressly agreed that Almita may disclose your personal information or financial information to our subsidiary and parent companies and businesses, and other affiliated legal entities and businesses with whom we are under common corporate control. All of our parent, subsidiary and affiliated legal entities and businesses that receive your personal information, financial information, or non-anonymous demographic information from us will agree to comply with the terms of this privacy policy with respect to their use and disclosure of such information.

SECURITY OF YOUR PERSONAL INFORMATION Your personal information is stored at secured locations either at our offices or at the offices of our authorized contractors. We retain your personal information for as long as we require it to fulfill the purpose that it was collected for.

To protect the confidentiality of your personal information, we employ administrative and technological safeguards appropriate to the sensitivity of your personal information. In addition, where personal information is provided to a third party for processing, we make sure, through our contracts with them, that your personal information is kept secure. Lastly, we take steps to ensure that your personal information is only accessible by personnel who have a legitimate business need to have access to it.

UPDATING YOUR PERSONAL INFORMATION We make reasonable efforts to keep your personal information current and accurate. For example, wemay use contracted third parties to update our records from time to time.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION You can access and correct your personal information by sending a written request to our Privacy Office at the address indicated below. At the time of your request, we may request you to provide specific information in order to permit us to verify your identity. In the event that any of your personal information is found to be incomplete or inaccurate, we will take reasonable steps to correct your personal information record.

Please note that there may be instances where we may not be able to permit you to access or correct your personal information. Examples of this could include personal information which:

contains references to another person(s), which would involve the disclosure of confidential information, could result in harm or loss to another person(s), could interfere with the activities of law enforcement agencies or statutory bodies, is not readily retrievable, or where the cost of retrieving it would be prohibitive or disproportionate to its value or usefulness, has already been destroyed due to legal requirements, or because its continued retention was unnecessary, is subject to solicitor-client or litigation privilege, or cannot be disclosed for legal reasons. WITHDRAWING CONSENT (OPTING-OUT) If you do not want to be contacted for product, service or marketing purposes, or if you want to be removed from our direct marketing programs, telemarketing, direct mail or e-mail lists, please contact us as indicated below. Except as required or permitted by applicable laws, you have the right at any time to withdraw your consent to our collection and use of your personal information. We will take steps following receipt of your written request to amend our records to reflect your request. Where you may choose to provide Almita with your email address, personal information, or any other information for the purposes of opting-out of receiving email solicitations, you agree that we may use and disclose that information as we deem appropriate in order to allow compliance with our internal Almita policies, and to take all steps we deem necessary in order to ensure compliance with the CAN-SPAM Act of 2003 (if applicable). As such, and without limiting the foregoing, email addresses or any other information you provide may be compiled into a suppression list or other database, and may be provided to third party publishers, advertisers or otherwise for the purposes “scrubbing” their own lists to ensure such third parties do not provide email solicitations in respect of Almita to opted out persons. However, Almita shall not be responsible for the consequences of any release, use or abuse of the information which has been provided to the third party in furtherance of the effecting the opt-out requests, whether such release, use or abuse by that third party was is in breach of any confidentiality agreements or otherwise.

Please note, however, that in certain circumstances such as matters relating to law enforcement and public or personal health, safety, security or property, or for the purpose of collecting monies owed to us, applicable laws may require or allow us to collect, use or disclose your personal information without your consent. In such circumstances, we will only disclose your personal information to the extent that it is required.

CHILDREN INFORMATION (APPLICABLE TO UNITED STATES DATA ONLY) In general, the Almita network is comprised of general interest/audience sites and is not directed at children under the age of 13. It is Almita’s policy for network sites to refrain from knowingly collecting personally identifying information from children 13 or under and to actively discourage children from providing such information at points of collection.

To the extent any network sites are or become directed at children 13 or under and knowingly collect personally identifying information from those children (such as full name, home address, email address, telephone number or any other information that would allow someone to identify or contact the child) it is Almita’s policy for such sites to include parental notice and/or consent features consistent with the Children’s Online Privacy Protection Act (United States). In short, and depending on the nature and intended use of the information at issue, sites collecting personally identifying information from children will provide parental notice or obtain verifiable parental consent as follows: in the case of notice, the network site sends an email to the parents or legal guardian of the child that informs them i) what information was collected, ii) what contact has been, and/or will be, made, and iii) that the parent may require deletion of such information and cessation of any contact; OR, in the case of consent, the network site informs parents or a legal guardian i) that the site wishes to collect personal information from the child, ii) that a parent’s or legal guardian’s verifiable consent is required for the collection, use and disclosure of the information, and iii) how the parent can provide consent.

A parent or legal guardian has the option to agree to the collection and use of the child’s information without consenting to the disclosure of the information to third parties. Network sites send a new notice and request for consent to parents and legal guardians if there are material changes in the collection, use or disclosure practices to which the parent or legal guardian had previously agreed.

Network sites do not send a notice to parents or legal guardians prior to collection of a child’s email address for the following activities:

contest entries; one-time online newsletter requests (parents are notified prior to future deliveries of the newsletter and given an opportunity to consent); electronic postcard or other e-greeting deliveries; providing notice and seeking consent to collect a child’s or parent’s email address; or responding to a one-time request from a child and then deleting the email address. At any time, a parent or legal guardian may revoke his/her consent or refuse to allow a network site further use of his/her child’s personal information and request that Almita delete the information. Effecting such a request can be accomplished using the contact information provided on the relevant network site. Please note that a site may terminate any service provided to the child if the deleted information at issue is reasonably necessary for the child’s participation in that activity.

CHANGES TO OUR PRIVACY POLICY From time to time, we may use information for new, unanticipated uses not previously disclosed in our privacy policy. As such, please review this privacy policy periodically as we may modify it from time to time. If our information practices change at some time in the future, we will notify all registered members of any change to this privacy policy either by posting a notification on the site or via email, unless you have opted-out of receiving email from us, and provide you with the ability to opt out of these new uses. If you are concerned about how your information is used, you should check back at our site periodically. Continued use of the site after changes are posted or emailed constitutes your acceptance or deemed acceptance of the terms as modified, regardless of whether the notice or email was successfully received, read, or lost during transmission. Each time you visit the site or provide us with information, by doing so you are accepting the practices described in this privacy policy at that time.

EFFECTIVE DATE This Privacy Policy is effective as and from the effective date shown below. We encourage you to visit this site frequently to view our most current Privacy Policy.

APPLICATION OF THIS POLICY This Privacy Policy does not apply to personal information that we may collect from employees of Almita, the protection of which is governed by other Almita policies.

Users should be aware that any third party links, whether text, graphic or animated, and whether appearing as banners, buttons or in pop-up windows, include a link to another page or website where more information is available about the particular product or service being advertised. This privacy policy only governs Almita network sites and clicking on links in ads (or anywhere else for that matter) will often take a user to a site outside the network, where information collection and use practices may differ from those employed by Almita. Please note that Almita’s privacy policy does not cover the web sites or web pages that link to the Almita Network of sites and services.

CO-BRANDED PAGES In some cases, Almita may enter into a promotional or commercial relationship with another company in which we prominently display their brand name or trademarks on pages of the site. These pages are known as “Co-Branded Pages” and these companies are known as “Co-Branded Companies.” If the page on which you submit information is a Co-Branded Page, or was accessed by clicking on a link on a Co-Branded Page, then we may share your personal information with the associated Co-Branded Company. Co-Branded Companies may use your personal information in accordance with their own privacy policies. You will need to contact Co-Branded Companies to instruct them directly regarding your preferences for the use of your personal information by them. Additionally, you agree that Almita may use and disclose all such information so submitted to such Co-Branded Companies in the same manner in which we are entitled to use and disclose any other information you submit to us. Some Co-Branded Pages may use cookies (see above) or may contain an action tag (also known as a beacon or a 1 pixel .gif file) that a third party may use to read cookies that it, or its clients, may have placed on your browser at other web sites before your visit to the Site. Further, such third parties may use the information collected through this technology to learn more about your visits to this Site and other websites in order to provide advertisements about goods and services of interest to you. When we disclose your financial information or personal information to a Co-Branded Company, as described above, we may also disclose to that Co-Branded Company your demographic information, other than the content of one-on-one communications between you and other members.

By purchasing, or registering or making reservations for, or downloading information on, products or services of third parties offered on the Almita site, or by participating in programs offered on the site that are administered by third parties and that require you to submit financial information in order to use them, you also consent to our providing your personal and financial information to those third parties. Additionally, if the page on which you submit information is a Co-Branded Page, or was accessed by clicking on a link on a Co-Branded Page, then we may share your financial information with the associated Co-Branded Company. Any of these various third parties may be authorized to use your financial information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control, and you agree that we are not responsible or liable for any of their actions or omissions. Any third party with whom we are allowed to share your personal information is authorized to use your personal information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control, and you agree that we are not responsible or liable for any of their actions or omissions. Those who contact you will need to be instructed directly by you regarding your preferences for the use of your personal information by them.

LIMITATIONS AND ADDITIONAL PROVISIONS In addition to the terms above, the obligations, responsibilities and entitlements of Almita in respect of your information shall be further subject to and be modified by the site Terms and Conditions (including but not limited to the provisions described as Disclaimer, Limitations of Liability, Indemnity and General)

FURTHER INFORMATION For information on Almita privacy practices, or if you have any questions, concerns or complaints, please write to us at: Almita Piling Inc., Re: Privacy, 4201 66th Street, Ponoka, Alberta, T4J 1J8.

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