PRIVACY POLICY

At Toro Group of Companies, we value your business and respect your right to privacy. We want you to feel secure about any private information that you provide to us, and have therefore outlined our Privacy Policy below.

This Privacy Statement has been adopted by Toro Group of Companies and by those organizations using the Toro Group of Companies trademarks under license from Toro Group of Companies (referred to collectively as “Toro Group of Companies “), in order to demonstrate their commitment to the protection of individual privacy. The following discloses the personal information collection, use and disclosure practices of Toro Group of Companies.

For the purposes of this Statement, “personal information” means information that is personally identifiable to individuals. “Non-identifiable information” means information that cannot be associated with or traced back to specific individuals with any certainty.

How and when Toro Group of Companies collects personal information

1. Toro Group of Companies collects personal information from individuals on a voluntary basis through surveys, contest entry forms, registration forms, questionnaires and transaction documents both online and offline. The personal information includes contact information (for example, name, mailing address, e-mail address, telephone number), demographic information, household information, preference information and transaction-related information.

Use of personal information by Toro Group of Companies

2. Toro Group of Companies uses personal information that it collects for the following:

  • To communicate with individuals
  • To understand individual needs
  • To promote and offer products, services and special offers that meet individual needs or that might be of interest to individuals based on information provided and approved by Toro Group of Companies.
  • To provide individuals with products or services that are requested or that is part of Toro Group of Companies ongoing service with its customers
  • To conduct, process and complete transactions with Toro Group of Companies customers

The information also enables us to develop and customize our products and services to better meet the needs and preferences of customers. Toro Group of Companies may, from time to time, contact individuals by electronic format, regular mail or telephone for any of the purposes set out above.

Disclosure of personal information by Toro Group of Companies

3. Toro Group of Companies does not sell, rent or trade personal information that it collects. Toro Group of Companies will not knowingly disclose personal information to any third parties except in the following circumstances:

  • When Toro Group of Companies has received consent to do so or under limited circumstances specifically described at such time as personal information is collected;
  • When Toro Group of Companies, in good faith, believes the law permits or requires such disclosure;
  • To affiliated and associated companies within the Toro Group of Companies and only for the purposes described in paragraph 2 above. These affiliated and associated companies and their respective employees are restricted from using the personal information for any other purpose other than as described in paragraph 2 above.
  • To its agents, professional advisors, promotional and marketing agencies, and to any other Third Parties in order to complete transactions, to process data and to service customers. These Third Parties and their respective employees are only provided with such personal information as is necessary to perform the services for which they have been contracted and are restricted from using the personal information for any other purpose other than as described in paragraph 2 above.
  • In the event of the sale of Toro Group of Companies, personal information may be one of the transferred business assets.

Retention of personal information by Toro Group of Companies

4. At such time as personal information is no longer required for the purposes stated in this Privacy Statement or other statutory requirements, such personal information will be made anonymous or destroyed.

Collection, use and disclosure of non-identifiable information

5. Toro Group of Companies collects and uses Non-Identifiable Information to assess the effectiveness of web site content and traffic. This allows Toro Group of Companies to improve the quality of visits to web sites managed by it by streamlining visitors’ ability to navigate these sites and developing featured programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analyses of the collective characteristics and behaviour of individuals, and to measure demographics and interests.

6. Toro Group of Companies also uses aggregate non-identifiable information it collects to inform its current and prospective sponsors and advertisers about the number of visits to its web sites, the demographic characteristics of these visitors and the number of times visitors have viewed and “clicked” on their advertisement(s). Toro Group of Companies also discloses to advertisers the overall demographics available regarding visitors who “clicked” on their advertisement. Aggregate non-identifiable information may be used to describe Toro Group of Companies services and products to third parties such as prospective business partners and financial institutions. In any of these circumstances, only non-identifiable information in an aggregate form and not personal information is disclosed.

Web sites operated by third parties

7. Web sites operated by Toro Group of Companies may contain links to other web sites that may collect personal information. This Statement does not extend to the data collection, disclosure, use and retention practices of such third parties and Toro Group of Companies does not assume any responsibility for the privacy practices, policies or actions of such third parties. Individuals should read the privacy policies of such third parties, and make an informed decision whether or not to visit such web sites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.

Safeguarding personal information

8. Toro Group of Companies has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. Personal information is stored in confidential databases and locations in the Greater Toronto Area. These sites have appropriate security measures in place to protect against the loss, misuse and alteration of personal information under the care and control of Toro Group of Companies. Any information transmitted via the Internet, however, may be intercepted by third parties. Toro Group of Companies does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. Toro Group of Companies employees are restricted from using and disclosing personal information collected by Toro Group of Companies other than in accordance with this Statement.

Accessing personal information

9. Individuals have the right to access, verify and correct or amend all of their personal information collected by Toro Group of Companies. Toro Group of Companies believes that it is imperative that personal information be as accurate, complete and up to date as is necessary for the purposes for which it is collected. Accordingly, to help Toro Group of Companies keep personal information as current as possible, Toro Group of Companies encourages individuals to amend inaccuracies and make corrections in their personal information collected by Toro Group of Companies as often as necessary. To access verify and correct or amend personal information, please send an email to the Privacy Officer at Toro Group of Companies at privacy@torogroupofcompanies.com or call at 905-738-5220.

How to File a Complaint

10. To file a complaint with Toro Group of Companies concerning the collection, use and/or disclosure of personal information, please send an email to the Privacy Officer at Toro Group of Companies at insert email or call at 905-738-5220. All complaints will be investigated by the Toro Group of Companies Privacy Officer as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints clearly and promptly and will be notified of any relevant steps taken or to be taken as a result of a complaint.

The choice to provide personal information or to receive certain information and promotional materials

11. Individuals always have the choice whether or not they wish to supply Toro Group of Companies with personal information. Individuals wishing to “opt-out” of receiving certain informational and promotional materials from Toro Group of Companies or who otherwise object to the collection, use and disclosure policies as provided under this Privacy Statement, are asked to contact the Privacy Officer at Toro Group of Companies by email at privacy@torogroupofcompanies.com or call 416-661-9290, extension #1427 .

Opt-out opportunities are also provided in other circumstances such as in certain promotional mailings. Individuals are reminded that the decision to withhold personal information or to object to the use and/or disclosure of personal information as provided in this Privacy Statement or in any agreement between such individuals and Toro Group of Companies, may, in certain instances, limit their ability to complete purchases of Toro Group of Companies products and services and limit their ability to access or take advantage of certain promotions and features.

Your personal information is obtained and used only with your consent that may be expressed or implied depending on the circumstance.

Comments and questions

12. Any comments or questions about this Statement, should be addressed to Toro Group of Companies as follows:

By mail:

330 Applewood Crescent

Concord, Ontario

L4K 4V2 Canada

Tel: +1 (905) 738-5220

Fax: +1 (905) 738-5481

info@toroaluminum.com

By email:

privacy@torogroupofcompanies.com

By phone:

905-738-5220

Effective date of Statement

13. This Statement has been adopted by Toro Group of Companies as of XXX XX, XXXX. Revisions to the Statement will be posted on www.torogroupofcompanies.com as soon as practical.