Privacy Policy

GIAMPAOLO GROUP OF COMPANIES – PRIVACY POLICY

The Giampaolo Group of Companies including, but not limited to its primary operating entities, Giampaolo Group Inc.;  Giampaolo Investment Ltd., Triple M Metal LP Niagara Metals LLC, Diamond Hurwitz LLC, and Premier Metals LLC (collectively, “Niagara Metals”); Matalco Inc., Venture Steel Inc. (each a “Company” and collectively the “Companies”) are committed to protecting your privacy. This policy sets out, in general terms, how the Companies collect, use, and disclose personal information.

Please read this policy carefully. By using our services and/or a Company website, providing us goods and/or services (including an employee and/or contractor) we deem you to have consented to the collection, use, and disclosure of your personal information for the purposes set out below.

WHAT PERSONAL INFORMATION DO WE COLLECT

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it is collected.

We may collect and use information about you that may include your name, address, phone number, vehicle license plate information, individual’s driver’s license number, DOB, and time of the transaction (s). This information is collected to create a prolific account which may be included in our Inventory and Transaction Management Systems to be used for business operations.

When interacting with customers we collect your business name and number, representative name and contact details, banking account details, and other identifiable information including the particulars above.

We maintain surveillance technology on all our premises, capturing video and still images.

We also collect information when the Company website is accessed by you. We collect this information to monitor and analyze cyber security incidents and threats, analyze and provide optimized user experience and is used to evaluate our customer base and provide optimized analysis for marketing of different sites between different regions within the Companies. The information collected may include but is not limited to:

• Logging information: we collect log information about your use of our website, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our website (third-party affiliates),
• Device information: we collect information about the computer or mobile device you use to access our website, including the hardware model, operating system and version, unique device identifiers,
• Mobile network information,
• Location information, and
• Demographics information.

WHY AND HOW WE COLLECT PERSONAL INFORMATION

Giampaolo Group Inc.

We collect your personal information for the following primary purposes:

• To identify you and provide you with service;
• To communicate with you, including to promote our products and services;
• To manage our business operation;
• To prevent fraudulent transactions;
• To maintain the security of our staff, equipment, and property;
• To meet our contractual, legal, and regulatory obligations;
• To improve accessibility requirements on our services; and
• To protect Company against the malicious cyber activity.

We collect personal information directly from you when you access Company’s website and contact us through the ‘Contact Us’ form/ page. In doing so, we provide notice in accordance with applicable privacy laws.

We also collect personal information captured through surveillance technology, including CCTV when you visit our operation centers. We also collect analytical information through third parties, including but not limited to social media, and direct and indirect advertisement for optimized marketing purposes.

Giampaolo Investments Limited

We collect your personal information for the following primary purposes:

• To identify you and provide you with service;
• To communicate with you, including to promote our products and services;
•  To maintain the security of our staff, equipment, and property;
• To prevent fraudulent transactions;
• To manage our business operation;
• To meet our contractual, legal, and regulatory obligations;
• To improve accessibility requirements on our services; and
• To protect Company against the malicious cyber activity.

We collect personal information directly from you when you access Company’s website and contact us through the ‘Contact Us’ form/ page. In doing so, we provide notice in accordance with applicable privacy laws.

We also collect personal information captured through surveillance technology, including CCTV when you visit our operation centers. We also collect analytical information through third parties, including but not limited to social media, and direct and indirect advertisement for optimized marketing purposes.

Triple M Metal LP and Niagara Metals

We collect your personal information for the following primary purposes:

• To identify you and provide you with service;
• To communicate with you, including to promote our products and services;
• To manage our business operation;
• To maintain the security of our staff, equipment, and property;
• To prevent fraudulent transactions;
• To meet our contractual, legal, and regulatory obligations;
• To inspect, audit, and confirm the material authenticity and weight count;
• To provide on-the-spot or hebdomadal cash payment;
• To provide B2B services;
• To improve accessibility requirements on our services; and
• To protect Company against the malicious cyber activity.

We collect personal information directly from you upon entry to our premises, during intake, and throughout your interactions with Triple M Metal LP. We also collect personal information directly from you when you access Company’s website and contact us through the ‘Contact Us’ form/ page. In doing so, we provide notice in accordance with applicable privacy laws.

We also collect personal information captured through surveillance technology, including CCTV when you visit our operation centers. We also collect analytical information through third parties, including but not limited to social media, and direct and indirect advertisement for optimized marketing purposes.

Matalco Inc.

We collect your personal information for the following primary purposes:

• To identify you and provide you with service;
• To communicate with you, including to promote our products and services;
• To manage our business operation;
• To meet our contractual, legal, and regulatory obligations;
• To improve accessibility requirements on our services;
• To maintain the security of our staff, equipment, and property;
• To prevent fraudulent transactions;
• To improve accessibility requirements on our services and
• To protect Company against the malicious cyber activity.

We collect personal information directly from you when you access Company’s website and contact us through the ‘Contact Us’ form/ page. In doing so, we provide notice in accordance with applicable privacy laws.

We also collect personal information captured through surveillance technology, including CCTV when you visit our operation centers. We also collect analytical information through third parties, including but not limited to social media, and direct and indirect advertisement for optimized marketing purposes.

Venture Steel Inc.

We collect your personal information for the following primary purposes:

• To identify you and provide you with service;
• To communicate with you, including to promote our products and services;
• To manage our business operation;
• To maintain the security of our staff, equipment, and property;
• To prevent fraudulent transactions;
• To meet our contractual, legal, and regulatory obligations;
• To inspect and confirm the material authenticity and weight count;
• To provide Business to Business services;
• To improve accessibility requirements on our services; and
• To protect Company against the malicious cyber activity.

We collect personal information directly from you when you access Company’s website and contact us through the ‘Contact Us’ form/ page. In doing so, we provide notice in accordance with applicable privacy laws.

We also collect personal information captured through surveillance technology, including CCTV when you visit our operation centers. We also collect analytical information through third parties, including but not limited to social media, and direct and indirect advertisement for optimized marketing purposes.

SOCIAL MEDIA

The Companies may also collect your personal information if you interact with us through our social media pages and accounts (e.g. Twitter, LinkedIn). For instance, we collect the personal information the respective social media platforms allow us to collect from our followers. We may also collect any content you upload to our social network pages (including photos or videos).

In addition, third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to LinkedIn) on our websites and apps may use cookies to gather information on your use of the websites and apps. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. The Companies encourage you to review the privacy policies of third parties as well.  The Companies disclaim any responsibility and/or liability in any fashion from any third party’s website including for the acts, omissions, or activity of such third party and/or user thereof.

Third parties involved may use these tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of our websites and apps to any other personal information they may have collected on you. We may also obtain and use analytical and statistical information from third-party social networks to help us measure the performance and effectiveness of the content we display on social networks, for example, by measuring impressions and clicks on the content the Companies promote.

DISCLOSURES OF PERSONAL INFORMATION

We may disclose your personal information to our affiliates, subsidiaries, third-party service providers, or advisers to fulfill the purposes as set out above and in accordance with applicable law. We also disclose this information to identify you as an individual or a business amongst the Companies and to secure our infrastructure from malicious and illegal activity. We may also disclose your personal information pursuant to a legal proceeding or as required by law, or in the course of a business transaction, including a merger, transfer, or sale of our assets or business.

USE AND DISCLOSURE OF AGGREGATE INFORMATION

We may use the personal information we collect to conduct research and analysis that supports our business. In doing so we may generate reports that contain data about our business. We only disclose such reports to third parties after removing any information that identifies individuals or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify individuals.

OUR USE OF SERVICE PROVIDERS AND 3^rd PARTY SERVICES

We may retain service providers and 3^rd party software and services that we authorize to process or store your personal information. For example, we may use service providers to utilize and process data to create and forecast reports. In doing so, we employ due diligence in selecting service providers, contracting with service providers, and administering our relationship with service providers. This includes requiring our service providers to complete our due diligence questionnaire before onboarding as this helps us evaluate their security and privacy posture as well as helping to identify what restrictions may need to be placed upon them. After onboarding limits their access and/or use of personal information to what is required to provide their services and requires our service providers to adhere to confidentiality as well as security requirements. The information which is processed digitally is encrypted in transit and at rest.

We operate in Canada, the United States, Costa Rica and Mexico and use service providers to process information stored in Canada and in the United States. Data that we and our service providers hold is subject to access under applicable local laws.

We are not responsible or liable for the use of your personal information that may be collected by a third-party website that has a link on any Company website. No Company is responsible or liable for the privacy practices or the content of any such third-party websites. The Company does not control, monitor or endorse the information gathering practices or privacy policies of any such third-party websites. Whenever applicable, the Company encourages you to read the privacy policy of any third-party website that has a link on a Company website.

OUR USE OF COOKIES AND OUR LOGGING PRACTICES

Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the owners of the site. You may manage your cookies through the use of your web browser settings.

We install cookies to administer our websites and help them function, for example, by remembering your language selection and keeping you logged into your account. We also use Google cookies (_ga and _gid) to help us identify the number of unique visitors to our websites and identify how visitors come to our websites and we use a Facebook cookie (_fpb) to help deliver advertising to people who have already visited our website when they are on Facebook or a digital platform powered by Facebook Advertising.

We collect data about individuals’ use of our websites and applications for security and administrative purposes. This includes login data, data about account changes (e.g. create an account, confirm email, recover password, change password), and data about technical errors and events.

OUR SAFEGUARDING OF PERSONAL INFORMATION

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. Your personal information may be stored in foreign jurisdictions, in which case it will be subject to foreign laws. We will store your personal information in accordance with our internal retention policies and/or as otherwise required or permitted by law.

We employ organizational, physical, and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is processed or stored.

We may share personal information amongst the Companies, including in Canada, the United States, Mexico, and Costa Rica (Quantum Lifecycle Partners LP only). Some of our service providers may also access, process, or store your personal information outside of the country where we are located and where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

CHILDREN’S GUIDELINES

No Company will knowingly collect information from children under the age of 13.

OUR STORAGE AND DISPOSAL PRACTICES

The information you have provided us is maintained in our management information system and is updated as new information is added. Records may remain on file even after you have terminated your business with the Companies. We will store your personal information in accordance with our internal retention policies and/or as otherwise required or permitted by law, after which your personal information will be securely destroyed or anonymized.

UPDATES TO THIS POLICY

We may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our website. If the changes we make are significant, we will provide a more prominent notice as required by applicable laws.

WHERE TO LEARN MORE

To learn more about the collection, use, disclosure, and protection of your personal information, to request access to or correction of your personal information, or to make a complaint, please contact the Privacy Office at [email protected] or by mail to: Privacy Officer, Giampaolo Group Inc., Suite 301, 1 Kenview Blvd., Brampton, ON L6T 5E6 Canada.

Effective date: March 31, 2023

REVIEW

This document is maintained by Giampaolo Group Inc.’s legal department.