Effective date: June 1, 2024

Liftow Limited, L.I.F.T. Training, Liftruck.com and MasonLift Limited, (“Liftow”, “we”, “our” or “us”) are committed to privacy. This privacy policy details how and for what purposes we collect, use and share personal information. This policy generally applies to personal information we collect whenever you interact with us, for instance if you visit our websites, contact us through social media and email, or apply for a job with us. It may also apply to personal information we receive from our clients (including trainees) and business partners. This policy does not apply to Liftow’s collection, use and disclosure of personal information about its employees.

1. Personal information

   In this policy, “personal information” generally means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, contact details, birth date and credit card number. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information, if it is, at all times, reasonably foreseeable in the circumstances that this information irreversibly no longer allows the individual to be identified directly or indirectly.

   Generally, “personal information” does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession such as the individual’s name, position name or title, work address, work telephone number, or work email address.

2. Types of personal information we collect

   We limit the collection of personal information to what is reasonably required to provide our products and services to you, to review your application, to respond to any other requests you may make and for the other purposes described below under Use of Personal Information. Depending on your interaction with us, we may collect the following categories of personal information:

   • Your name and contact information, which may include your email address, home address and phone number.
   • Job-related information, such as information about your work experience and education, when you apply for a position with us.
   • Credit and other background checks. If you apply for a job, we may perform a credit and background check with your consent.
   • Video surveillance and call recording. As a security measure for visitors and occupants of our premises (including our showrooms) and to maintain the security of our buildings, we can use video surveillance at various locations in our premises. If you call our customer service, we may also record calls.
   • Transactional and other financial information, such as payment methods and preferences, billing and banking information when you register to one of our training programs (e.g., credit card number and expiry date or chequing account transit numbers which are required to process a donation).
   • Information you provide to us through our social media accounts. We are present on social media platforms, such as Facebook, Instagram, YouTube and LinkedIn. When you interact with our social media accounts, for example, if you “like” our page or make comments, we may collect certain information about you, such as your name and profile picture. The information we collect depends on what these social media platforms share with us based on the privacy settings you have selected. We suggest you consult the privacy policies of these social media platforms to learn more.
   • Information related to online activity, including IP addresses, date and time of your visit, your time zone, your browser and operating system, the sections you visited on our websites and your language preferences. We may collect this information from website visitors through the use of Cookies and similar technologies.
3.  How we collect personal information

   We collect personal information in a variety of ways, including:

   • Directly from you. We may collect personal information directly from you under some circumstances, for instance if you contact us (including by email, social media, phone, etc.), if you apply for a position with us (including on careers website and/or through a third party), if you visit our offices or showrooms, if you meet with our representatives during our training classes, or through your business interactions with us.
   • From our business partners and clients. If you are an employee of a client or business partner of Liftow, your employer may provide us with personal information about you, as relevant to our business relationship between Liftow and your employer, including for our corporate training programs.
   • Through technologies we use on our websites. We collect certain types of information electronically through your contact with our websites using technologies (either our own or third-party technologies) such as cookies and web beacons (see Cookies and similar technologies for more details).
   • From third parties. In certain cases, we may collect personal information from other categories of third parties, but only with your consent or as permitted or required by applicable law. Third parties may include credit report agencies or background check providers.
4. Use of personal information

   We may use your personal information for the following purposes:

   • Selling our products and providing our services. We use personal information as necessary to sell our products and provide and deliver our services (including after-sale services).
   • Communicating with you. If you contact us with a question or inquiry, we may use your personal information to respond to you. We may also communicate with you for business development purposes and to promote our services and offers.
   • Processing job applications. If you apply for a position with us, we may use your personal information as necessary to process and evaluate your application.
   • Managing our business. We use your personal information for several reasons in connection with our business operations, which may include exercising due diligence to prevent or reduce our commercial risk and to ensure the security of our information, system or network. We may also use information for internal business analytics purposes (when possible or when required by law, we will de-identify information before using it for such purposes).
   • Managing our websites. We use information we collect from website visitors to manage and improve our websites and to remember your preferences (see Cookies and similar technologies for more information).
   • For other purposes as permitted or required by law. For example, we may use the information we collect to protect the security of that information and our websites or to comply with a legal requirement, if necessary. We may also request your consent to use your personal information for other specific purposes.
5. Sharing your personal information

   We may share your personal information as follows:

   • Among ourselves and within our corporate group. We may share personal information among us for the purposes described in this policy, most notably to comply with applicable laws, regulations and requirements.
   • With Toyota Material Handling. We may share your personal information with the manufacturer of the products we distribute, Toyota Material Handling, for the purposes described in this Privacy Policy, including for warranty-related purposes, the whole in accordance with applicable law.
   • With our service providers. We may transfer your personal information to other organizations and businesses that provide services to us, such as backup and server hosting providers, IT software, maintenance and analytics providers, professional services, insurance services, recruitment services. We require these service providers to protect personal information with appropriate security safeguards and to limit their use of personal information to what is necessary to carry out their mandate.
   • In the context of the sale or transfer of our business or other transaction. We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction.
   • Other permitted reasons. We may share your personal information when permitted or required by applicable law. This may be the case, for instance, if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety or of our customers, or others.
6.  Cookies and similar technologies

   We may collect certain types of information electronically through your interaction with our websites using technologies (either our own or third-party technologies) such as cookies. Cookies are small text files that are stored on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. Thus, cookies allow you to log in quickly when you visit our sites.

   The cookies are set by our websites and/or by the external web services in order to maintain the full functionality of our websites, improve its user-friendliness or pursue the purpose declared with your consent. The cookie technology also enables us to identify individual visitors by means of pseudonyms, e.g. an individual or random ID, so that we are capable of offering more individualized services and remember your preferences.

   We use Google Analytics to analyze your use of our websites, generate reports for us on the activities of visitors to our websites, and provide other services related to the use of the website. This information is not transmitted to us in a form that can identify you. If you would like to opt out of Google’s ad settings, please go to www.google.com/ settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use certain features of our websites.

7. What are your privacy choices?

   By purchasing our products, using our services, interacting with us, for instance when you visit our websites or contact us through social media and email, or when applying for a job with us, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information. We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated in this privacy policy, in compliance with applicable privacy laws.

   Upon reasonable notice, you may withdraw your consent to the use and disclosure of your personal information by us, subject to legal or contractual restrictions. To withdraw your consent, please send us a written request using the contact information listed in the Contact us section below. Withdrawing your consent may impact the services we are able to provide to you and to your employer (for corporate training).

8. Accessing and correcting your personal information

   Liftow respects your right to access your personal information and to request its rectification if it is inaccurate, incomplete or equivocal, subject to any applicable legal restrictions.

   You also have the right to obtain more information about our processing of your personal information, including the categories of individuals who have access to your personal information within our organization and the applicable retention period for your information. To exercise these rights, please use the contact information listed in the Contact us section below.

9.  How do we protect your personal information?

   To protect your personal information, we employ organizational, physical and technological safeguards. Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of personal information in our possession. We also use these safeguards when we dispose of or destroy your personal information.

10. How long do we keep your personal information?

    We store your personal information for as long as is necessary to provide our services to you, to manage our business operations, and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed or anonymized (so that it is, at all times, reasonably foreseeable in the circumstances that the information irreversibly no longer identifies you directly or indirectly).

11. Cross-border transfers of personal information

    Some of our external third-party service providers and partners, including Toyota Material Handling, Inc., are based outside of your province or residence or Canada, including in the United States, and their processing of your personal information will therefore result in the transfer of information outside of your province of residence and of Canada. We have entered into or will enter into a written contract with any third party, providing the protections required by law to ensure the protection of your personal information, in compliance with applicable Canadian privacy laws.

    Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, your personal information may be subject to the laws of a foreign jurisdiction, including any law that permits or requires the disclosure of information to law enforcement or national security authorities upon request.

12. Data Governance

    We maintain policies and practices, which ensure the protection of your personal information, including:

    • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
    • A designated Privacy Officer to monitor our compliance with applicable data protection laws;
    • Employee privacy and data security training;
    • Procedures for receiving, investigating and responding to complaints or inquiries regarding our information handling practices, including any security incidents involving personal information;
    • Framework governing the retention and destruction of personal information, as mentioned above under How long do we keep your personal information?; and
    • Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate privacy protections and standards.
13. Changes to the privacy policy

    We may make changes to this policy from time to time. Any changes we make will be effective when we post the revised policy on our websites. If we make any significant changes to the policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements that may apply. The “Effective Date” at the top of this policy indicates when it was last updated.

14.  Contact us

    If you have any questions or complaints about how we handle your personal information or if you want to exercise your privacy rights, please contact our Privacy Officer at: tracy.robinson@liftow.com.