Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) describes the types of information Graymont Limited or its subsidiaries (collectively, “Graymont”, “we”, “us” or “our”) may collect about you or that you may provide when you visit the site www.graymont.com(our “Site”) or interact with our Site, applications, portals, products, or services (collectively, our “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Information We Collect About You and the Purpose for Collection

We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“personal information”). Graymont may collect the following categories of personal information from its Site visitors, customers, shareholders, and business contacts for the following purposes:

Category	Examples	Purpose
Identifiers	A real name, postal address, IP address, email address, driver’s license number, passport number, or other similar identifiers.	(a) Performance of a contract, including to enable product purchase and delivery; (b) Necessary for our legitimate business interests, including to fulfill contracts and approve credit limits for customers, and to enable our suppliers to provide us services; (c) To communicate with shareholders; (d) Necessary to comply with a legal obligation, for example, transparency legislation for shareholders.
Consumer Records	A name, signature, or financial information.	(a) Performance of a contract, including to enable product purchase and delivery; (b) Necessary for our legitimate business interests, including to fulfill contracts and approve credit limits for customers, and to enable our suppliers to provide us services; (c) To communicate with shareholders, including to pay dividends; (d) Necessary to comply with a legal obligation.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a Site, application, or advertisement.	(a) Necessary for our legitimate interests, including for operation of the Site, marketing and security.
Professional or employment-related information	Current or past job history.	(a) Necessary for our legitimate business interests, including to assess job applicants.
Sensitive personal information	Graymont does not collect sensitive personal information without your consent.

We may also collect additional categories of information with your consent for the purposes identified to you at the time of collection.

We collect this information:

Directly from you when you provide it to us, for example by corresponding with us or filling in forms or questionnaires.
Directly from you when you register for an account on our Site or portals operated by Graymont including recruitment, shareholder, customer, and vendor portals.
From third parties, for example, our business partners.

We also collect information from you when you:

Conduct investment transactions. You may be required to provide financial information when you invest in the company.
Place orders. You may be required to provide financial information before placing an order.
Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Anonymity

With the exception of the information we need to collect for the proper functioning of the Site, where practicable, we will give you the option of not identifying yourself or using a pseudonym when interacting with us. If you do not give us the requested personal information, or if the information you give us is incomplete or inaccurate, you may not be able to use certain features and our ability to meet our obligations to you, to provide services or process any request or complaint may be adversely affected.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to and usage of our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use our Services.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

How We Use Your Information

In addition to the purposes described above, we also use information that we collect about you or that you provide to us, including any personal information:

To provide our Services, including to process your orders, process payments, and communicate with you about your orders or requests, or to provide you with information about our Services.
To communicate with investors.
To comply with legal obligations, such as transparency legislation relating to investors.
To present our Site and its contents to you.
To administer our vendor, recruitment, customer or shareholder portals.
To perform research and analysis and develop our Services.
To provide you with technical or customer support and respond to any complaints or feedback you may have.
To manage our relationships with customers, suppliers, contractors, and investors, including for administrative and record keeping purposes and to notify you about changes to our Services.
To fulfill any other purpose for which you provide it or in any other way described when you provide the information.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
For any other purpose with your consent.

We may also use the information we have collected from you to enable us to directly communicate with you about products, services, special offers, promotions, or events that may be of interest to you. If you do not wish to receive these marketing communications, please let us know by utilizing the opt-out/unsubscribe options in our communications or by contacting us directly using the contact information below.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business. For example, financial institutions for payment processing, delivery and shipping providers, information technology service providers, marketing services, or professional service advisors.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Graymont's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Graymont is among the assets transferred.
To fulfill the purpose for which you provide it or with your consent.
For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Graymont, our customers, our suppliers, our shareholders, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sales and “Sharing” of Personal Information

Graymont does not sell or share (for targeted or cross-context behavioral advertising) your personal information.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your contact information used by Graymont to promote our own products or services, you can opt-out by utilizing the unsubscribe method in our communication or by sending us an email stating your request to privacy@graymont.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Graymont as a result of a product purchase, warranty registration, product service experience or other transactions.

Accessing and Correcting Your Information

Under applicable law of the jurisdiction where you reside and under certain circumstance, you may have rights regarding your personal information, you may have specific rights regarding your personal information. This section describes the rights you may have and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You may have the right to request that Graymont disclose certain information to you about our collection and use of your personal information.

Deletion Request Rights

You may have the right to request that Graymont delete any of your personal information that we collected from you and retained, subject to certain exceptions. If an exception applies, we will advise you of the applicable exception and the reason for denying your request.

Correction Request Rights

You may have the right to request that Graymont correct any inaccurate personal information we may hold about you.

Object to processing

Where we rely on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing

You can ask us to suspend the processing of your personal information (i) if you want us to establish the information's accuracy; (ii) where our use of the information is unlawful but you do not want us to erase it; (iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information to you or to a third party

We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Non-Discrimination

We will not discriminate against you for exercising any of your rights.

Exercising Rights

To exercise your rights as described above or to designate an authorized agent to exercise rights on your behalf, please contact us at one of the following options:

Sending us an email at privacy@graymont.com or calling us at 1 604 207-4292 or 1 604 276-9331 or toll free at 1 866 207-4292 or 1 866 276-9331.
Sending us mail at Attn: Privacy Officer, 200-10991 Shellbridge Way, Richmond, BC, V6X 3C6, CANADA.

We may need to validate your request. In order to validate your request, we may ask you for the following information: your name, your company, and the circumstances of your prior contact with Graymont, and contact information. Only you or an authorized agent may make a verifiable consumer request related to your personal information. To designate an authorized agent to make a request on your behalf, please provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent. You may send your request to us via email at privacy@graymont.com or via mail at the address listed above.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@graymont.com or write us at: Attn: Privacy Officer, 200-10991 Shellbridge Way, Richmond, BC, V6X 3C6, CANADA.

Cross-Border Data Transfers

Where permitted by applicable law, we may transfer the personal information we collect about you to Canada, Australia, the Philippines, Malaysia, New Zealand or the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country/province/state, as necessary for the purposes set out in this Privacy Policy. The purpose for this transfer may be Graymont’s internal use, as well as for use by select financial, insurance, physical security, information, or payroll service providers on Graymont’s behalf, all in relation to your employment or contractual relationship with Graymont. We have implemented appropriate safeguards, including internal privacy policies and contractual obligations with the service providers, to secure the transfer of your personal information and ensure that your personal information is treated in a way that is consistent with and which respects applicable privacy legislation.

If you are located in European Union, we may transfer your personal information to Canada. The legal basis for this transfer Adequacy Decision (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32002D0002).

Retention Period

We store your personal information for no longer than necessary for the purposes for which it was collected, including for the purposes of satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information; and the applicable legal requirements.

Accuracy

We keep your information as accurate, complete, and up to date as is necessary for the purpose for which it is used. You must keep us informed of changes in your personal information.

Safeguards:

We protect your personal information by using safeguards that are appropriate to the sensitivity of the information. All employee records and files are secured in an appropriate manner and access to those records and files is restricted to those employees who require access for business reasons.

Age of Majority

Our Services are not intended for children under the legal age of majority in the applicable jurisdiction. No one under the legal age of majority may provide any information through our Services. We do not knowingly collect personal information from children. If you are a child under the legal age of majority, do not use or provide any information through our Services. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us at privacy@graymont.com.

Changes to Our Privacy Policy

It is our practice to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Site home page or through your customer or shareholder portal. You are responsible for ensuring we have up-to-date active and deliverable contact addresses for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: privacy@graymont.com or by mail: Attn: Privacy Officer, 200-10991 Shellbridge Way, Richmond, BC, V6X 3C6, CANADA.

Published: December 2023