Privacy Statement

PRIVACY POLICY

Last updated: June 11, 2026

We, Canadian General-Tower Limited, its Affiliates and subsidiaries, (“CGT”, “the company”, “we”, “our”, ”us”) values the importance of protecting your privacy and personal information. We have developed our Websites (“Site”) to provide you information about our company and our products and services. We collect certain information from you when you visit our Site, including personal information. We have written this Privacy Policy to describe what information we collect, how we collect it, how we use it and how we share it when you visit our Site. We have also described the methods we use to protect the information we collect.

We use Your Personal Data to provide and improve the Service. By using the Site, You agree to the collection and use of information in accordance with this Privacy Policy.

WE COLLECT PERSONAL INFORMATION

You may provide us with certain Personal Information when visiting our Site. Personal Information means information which a person could use alone or in combination to identify or locate an individual. For instance, your name, address, email address, telephone number, and employment application information are all Personal Information.

We collect Personal Information from you if you request information from us, apply for a job, fill out a form, or otherwise enter your Personal Information on the Site. We may combine Personal Information with Electronic Data or information obtained from third-parties. To the extent we combine that data, we will treat it as Personal Information unless we use it in a de-identified form.

WE COLLECT ELECTRONIC DATA

When you visit the Site, third-parties service providers that we use to operate the Site will automatically collect electronic data regarding your visit (“Electronic Data”). Unless otherwise provided by law, Electronic Data does not include Personal Data. However, we will treat Electronic Data as Personal Data (i.e. – IP address or geographic information) where required by law. In particular, we may collect:

IP addresses (the address assigned to the computers and other devices from where you access the Internet);
Name of your internet company;
The number of the device you are using to access the Site;
Your approximate geographic location;
The type of web browser you are using to get to the Site;
The pages you access on our Site and the time you spent on the Site; and
The websites you access before and after visiting our Site.

HOW WE USE PERSONAL INFORMATION AND ELECTRONIC DATA

We may use and share your Personal Information and other Electronic Data for the following reasons:

Communicate with you;
Take job applications;
Provide customer support;
Marketing Events, Conferences and Surveys;
For business transfers;
For other purposes.

Communications: If you communicate or correspond with us by email, through postal mail, via telephone or through other forms of communication, including our customer service center, we may collect the information you provide as part of those communications. For example, if you correspond with us through email, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of CGT services, product requests, conferences, technical document publications, or other services; or to keep a record of your complaint, accommodation request, and similar purposes.

Job Application: CGT collects personal information if you apply for a job at CGT. Personal information that we collect includes names, mobile phone numbers, e-mail addresses, educational background, work experience, and/or other background information relevant to your application. If you do not provide such information, we may not be able to handle your application.

Customer Support: CGT collects personal information from you when you complete an online request form for the Sites. Personal information that we collect includes your username, first and last name, e-mail address, company/employer name, phone numbers. If you do not provide such information, you may not be able submit a request for information or documents online.

Marketing Events, Conferences and Surveys: We may host events that include in-person and virtual conferences, training, knowledge sharing and webinars. If you register for an event, we will access the information in your to provide you with information and services associated with the event. We may also ask for additional information during the registration process.

For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

COOKIES

The company may use cookies to keep track of your visit to our Sites. A “cookie” is a small amount of data sent from a server to your browser and stored on your computer’s hard drive. Other tracking technologies work similarly to cookies and place a small amount of data on your devices to monitor your website activity to allow us to collect information about how you use our Sites. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored on your computer. Please refer to your browser instructions which will give you more information. Please be advised that certain sections or functionalities of the Sites may be inaccessible to you if your browser does not accept cookies. We do not currently respond to browser do-not-track signals.

Please refer to our Cookie Policy for more details regarding our use of Cookies.

We may share Your Personal Data in the following situations:

With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods (“up to”) and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

Usage Data
Website analytics data (cookies, IP addresses, device identifiers): up to 24 months from the date of collection, which allows us to analyze trends while respecting privacy principles.
Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

We may retain Personal Data beyond the periods stated above for different reasons:

Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
Legal claims: Data is necessary to establish, exercise, or defend legal claims.
Your explicit request: You ask Us to retain specific information.
Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

Deletion: Personal Data is removed from Our systems and no longer actively processed.
Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area (“EEA”) and the United Kingdom (“UK”), where data protection laws may differ.

Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as:

The European Commission’s Standard Contractual Clauses (“SCCs”) and/or the UK International Data Transfer Agreement (“IDTA”) or the UK Addendum to the SCCs (as applicable)
Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimization, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to work with our Service Providers (for example, hosting, analytics, email delivery). You may contact Us using the details in the “Contact Us” section of Our Privacy Policy to request further information about the safeguards We use for international transfers, including copies of relevant contractual protections (redacted where necessary).

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your Account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances (for example, while We verify accuracy or consider an objection).
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data 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.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page(s) including, but not limited to, https://www.facebook.com/cgtsocial.ca/, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal Data or contact Facebook online, or by mail: Meta Platforms, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the “Use of Your Personal Information” section or contact us.

To submit a request to limit the use or disclosure of sensitive personal information, please contact Us using the methods listed in the “Contact Us” section of Our Privacy Policy.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your Account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).

Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Data Controller, for the purposes of the GDPR (General Data Protection Regulation) , the Company is the Data Controller. The Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Facebook Fan Page is a public profile named cgtsocial specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/cgtsocial.ca/

GDPR refers to EU General Data Protection Regulation.

Personal Data (or “Personal Information”) is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
We use “Personal Data” and “Personal Information” interchangeably unless a law uses a specific term.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Policy or the practices described herein, you may contact us via our webpage https://www.cgtower.com/company/global-location/#contact, by email at sales@cgtower.com by telephone at 519-623-1633, or by mail at Canadian General-Tower Limited, 52 Middleton Street, P.O. Box 160, Cambridge, ON, N1R 5T6