WEBSITE TERMS OF USE AND PRIVACY POLICY

Last updated: September 22, 2026

OVERVIEW AND EFFECTIVE DATE

This Website Terms of Use and Privacy Policy apply to ASPAC Developments Ltd. and ASPAC Projects Limited (collectively, "Company", "We", "Us", or "Our") and each customer, prospective customer, visitor, and user of our website, products, or services ("You" or "Your").

This document is organized into four parts: Part A sets out the terms governing use of the Website; Part B explains our privacy practices; Part C addresses CASL and marketing communications; and Part D provides contact and complaint information.

PART A — WEBSITE TERMS OF USE

By accessing or using the Website, You agree to use it only for lawful purposes and in accordance with these Terms of Use.

You must not use the Website in any way that:

Violates any applicable federal, provincial, local, or international law or regulation, including laws relating to data export, intellectual property, privacy, publicity rights, or other legal rights.
Violates the terms of use of any third-party website linked to the Website, including any third-party social media website.
Includes, uploads, transmits, activates, or distributes malware, viruses, harmful code, or other technology that may harm, disrupt, or impair the Website, our systems, or our operations.
Provides or contributes any false, inaccurate, misleading, unlawful, defamatory, abusive, hateful, discriminatory, obscene, threatening, harassing, or otherwise objectionable material.
Restricts or inhibits anyone’s use or enjoyment of the Website, harms the Company or Website users, or exposes the Company or any user to liability.

The information on this Website is provided for reference and general information purposes only. It is not comprehensive and does not constitute investment, legal, or other professional advice. We do not warrant that the Website or its contents are complete, accurate, current, secure, uninterrupted, error-free, or free from viruses. To the fullest extent permitted by law, we are not liable for any loss or damage arising from use of, access to, or reliance on the Website or any linked website.

We reserve the right to modify the information on the Website at any time without notice. Illustrations, renderings, specifications, and materials shown on the Website are artist’s impressions or approximations only and may differ from the completed project. Nothing on the Website constitutes an offer for sale; any such offering may only be made by disclosure statement or other document required by applicable law. Errors and omissions excepted.

If there is any inconsistency or ambiguity between the English version and any translated version of this document, the English version will prevail.

We may update these Terms of Use from time to time by posting the revised version on the Website. Your continued use of the Website after an update constitutes acceptance of the revised Terms of Use.

PART B — PRIVACY POLICY

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with the Website and our related interactions with You.

Privacy laws in Canada generally define "personal information" as information about an identifiable individual, including information that can be used on its own or with other information to identify, contact, or locate a person.

This Privacy Policy applies to information we collect, use, or disclose about You:

On this Website.
In person when we interact with You.
In email, text, and other electronic messages between You and this Website.
When You interact with our advertising or applications on third-party websites and services, if those advertisements or applications include links to this Privacy Policy.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about You. If You follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies, and we do not accept any responsibility or liability for these policies or their collection, use, and disclosure of Your personal information. We do not control these third-party websites, and we encourage You to read the privacy policy of every website You visit.

Please read this Privacy Policy carefully. If You do not agree with our practices, You should not use the Website. By accessing or using the Website, You indicate that You understand and consent to the practices described in this Privacy Policy, as updated from time to time.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about You, including:

Personal information, meaning information that can reasonably be used to directly or indirectly identify You, such as Your name, mailing address, email address, telephone number, IP address, username or similar identifier, billing and account information, or other identifier used to contact You.
Business contact information, meaning information related to Your business role, including:
- title;
- duties;
- business address;
- business email address; and
- business telephone number.
Non-personal information, meaning information that does not directly or indirectly identify You, such as demographic, statistical, or aggregated information.
Technical information, including browser type and version, time zone setting, browser plug-ins, operating system, platform, internet connection, device information, and Website usage details.
Website interaction information, including URLs, clickstream data, date and time of visits, products viewed or searched for, page response times, download errors, length of visits, page interactions, and methods used to browse away from the Website.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect Your information, including through:

Direct interactions with You, such as when You complete forms, contact us by phone or email, or otherwise communicate with us.
Automated technologies or interactions, as You navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Third parties or publicly available sources, for example, our business partners.

INFORMATION YOU PROVIDE TO US

The information we collect directly from You on or through the Website, in person, by phone, or by other means may include:

Information that You provide such as by interacting with us in person, on the phone, or filling in forms on our Website. This includes information provided at the time of accessing, using, receiving, or requesting any of our services, activities, products, or goods; interacting with our Website; and/or requesting further services or products. We may also ask You for information when You report a problem with our Website.
Records and copies of Your correspondence (including email addresses), if You contact us.
Your responses to surveys that we might ask You to complete for research purposes.
Details of transactions You carry out through our Website and of the fulfillment of Your orders. You may be required to provide financial information before placing an order through our Website.
Your search queries on the Website.

COOKIES AND AUTOMATIC DATA COLLECTION TECHNOLOGIES

As You navigate through and interact with our Website, we (or our agents) may use cookies or other automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

Details of Your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Website.
Information about Your computer and internet connection, including Your IP address, operating system, and browser type.

The information collected automatically helps us operate, secure, personalize, and improve the Website, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about Your preferences, allowing us to customize our Website according to Your individual interests.
Speed up Your searches.
Recognize You when You return to our Website.
Evaluate use of the Website to help improve the facilities, services, and products offered by us.
Compile aggregate statistics about You or our users to analyze site usage.
Detect, prevent, or otherwise address fraud, security, or technical issues.
Improve the Website’s performance and enhance Your online experience.

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 Website. 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 Website.
Analytics and preference cookies. We may use session cookies, analytics cookies, and preference cookies to operate the Website, understand how visitors use it, improve Website performance, and display content properly.
Flash Cookies. Certain features of the Website may use local stored objects or Flash cookies to collect and store information about Your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings used for browser cookies.
Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

HOW WE USE YOUR INFORMATION

We use information that we collect about You or that You provide to us, including any personal information:

To present our Website and its contents to You.
To provide You with information, products, or services that You request from us.
To fulfill the purposes for which You provided the information or that were described when it was collected, or any other purpose for which You provide it.
To provide You with notices about Your account or billing.
To carry out our obligations and enforce our rights arising from any contracts with You, including for billing and collection or to comply with legal requirements.
To notify You about changes to our Website or any products or services we offer or provide through it.
To improve our Website, products, services, marketing, customer relationships, and customer experiences.
To allow You to participate in interactive features, social media, or similar features on our Website.
To measure or understand the effectiveness of the advertising we serve to You and others, and to deliver relevant advertising to You.
In any other way we may describe when You provide the information.
To communicate with You about matters related to the Website, products, services, or transactions.
To provide, manage, and arrange goods or services offered by us or by our service providers, vendors, or suppliers.
To determine eligibility for products, services, privileges, benefits, or other advantages offered by us or our affiliates or partners.
To understand and respond to Your needs and preferences.
To keep our contact information accurate and up to date.
To host and administer the Website, process and store data, and perform technology-related functions.
For any other purpose with Your consent.

We may also use Your information to contact You about our own or third parties’ goods and services that may be of interest to You, as permitted by law. If You do not want us to use Your information in this way, You may use the unsubscribe mechanism in our emails or contact us at [email protected].

We may use the information we have collected from You to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose Your personal information for these purposes without Your consent, if You click on or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria.

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 that You provide as described in this Privacy Policy:

To our subsidiaries and affiliates.
In accordance with applicable law, 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where personal information held by us about our customers and users is among the assets transferred.
To advertisers and advertising networks that require aggregated or non-identifying information to select and serve relevant advertisements to You and others. We do not disclose identifiable personal information to advertisers for this purpose without consent.
To third parties to market their products or services to You, where You have consented or where otherwise permitted by law.
To contractors, service providers, vendors, suppliers, persons in the commerce distribution chain, and other third parties we use to support or provide our business, services, or products (including third parties that provide services or goods to you or us and analytics and search engine providers that assist us with Website improvement and optimization including Google Analytics).
To fulfill the purpose for which You provide it.
For any other purpose disclosed by us when You provide the information.
With Your consent.

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, in accordance with applicable law.
To enforce or apply these Terms of Use, this Privacy Policy, or other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information to contractors, service providers, and other third parties that support or provide our business, services, or products. We require those parties to keep personal information confidential, use it only for authorized purposes, and process it in a manner consistent with this Privacy Policy and applicable law.

We may process, store, and transfer Your personal information outside Canada, where privacy laws may differ from Canadian law. In those circumstances, foreign governments, courts, law enforcement, or regulatory agencies may be able to access Your personal information under applicable foreign laws. When we engage service providers, we require them to protect personal information using privacy and security safeguards consistent with this Privacy Policy and applicable Canadian privacy legislation.

By submitting or providing personal information, or by engaging with the Website, You consent to the transfer, storage, and processing described in this Privacy Policy.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide You with choices regarding the personal information You provide to us. The following mechanisms provide control over Your information:

Cookies. 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, some parts of the Website may not be accessible or may not function properly.
Third-party advertising. If You do not want us to share Your personal information with unaffiliated third parties for promotional purposes, You may opt out by using the unsubscribe mechanism in our emails or by contacting us at [email protected].
Promotional offers from the Company. If You no longer want us to use Your contact information to promote our own or third parties’ products or services, You may opt out by using the unsubscribe mechanism in our emails or by contacting us at [email protected]. This opt-out does not apply to transactional, service-related, or legally required communications.

DATA SECURITY

The security of Your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of Your information also depends on You. Where we have given You (or where You have chosen) a password for access to certain parts of our Website, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect Your personal information, we cannot guarantee the security of Your personal information transmitted to our Website. Any transmission of personal information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain Your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or de-identify Your personal information. We reserve the right to use and disclose such anonymous and de-identified data for any legitimate business purpose without further notice to You or Your consent.

CHILDREN UNDER THE AGE OF MAJORITY

Our Website is not intended for children under the age of majority in their jurisdiction of residence. We do not knowingly collect personal information from children under the age of majority. If You are under the age of majority, do not use the Website or provide any personal information to us. If we learn that we have collected personal information from a child under the age of majority without appropriate consent, we will delete that information. If You believe we may have information from or about a child under the age of majority, please contact us at [email protected].

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about You is accurate and current. Please keep us informed if Your personal information changes. By law You have the right to request access to and to correct the personal information that we hold about You.

If You want to review, verify, correct, delete, or withdraw consent to the use of Your personal information, You may email us at [email protected]. We may refuse a request where required or permitted by law, including where the change would make the information incorrect. If a fee applies to an access request, we will notify You in advance.

We may request specific information from You to help us confirm Your identity and Your right to access, and to provide You with the personal information that we hold about You or make Your requested changes. Applicable law may allow or require us to refuse to provide You with access to some or all of the personal information that we hold about You, or we may have destroyed, erased, or made Your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide You with access to Your personal information, we will inform You of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to Your personal information, subject to exceptions set out in applicable privacy legislation or other law. Examples of such exceptions include:

Information protected by solicitor-client privilege.
Information that is part of a formal dispute resolution process.
Information that is about another individual that would reveal their personal information or confidential commercial information.
Information that is prohibitively expensive to provide.

If You are concerned about our response or would like to correct information we have provided, You may contact our Privacy Officer at [email protected].

WITHDRAWING YOUR CONSENT

Where You have consented to the collection, use, disclosure, or transfer of Your personal information, You may withdraw that consent where permitted by law by contacting us at [email protected]. If You withdraw consent, we may be unable to provide certain products or services, and we will explain the impact at the time.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time by posting the revised version on our Website.

The date this Privacy Policy was last revised appears at the top of the page. You are responsible for periodically visiting our Website and reviewing this Privacy Policy for changes.

If You have questions about our privacy practices, wish to exercise privacy rights, or wish to challenge our compliance, please contact us using the information in Part D.

PART C — CASL AND MARKETING COMMUNICATIONS

If You subscribe to receive communications from us or our affiliates, we may send You a confirmation email regarding Your communication preferences.

You may unsubscribe from commercial electronic messages by using the unsubscribe mechanism in our emails or by contacting us at [email protected]. We may continue to send transactional, service-related, or other communications permitted or required by Canada’s Anti-Spam Legislation and other applicable laws.

Opt-In

Where required, You will be given an opt-in choice when You subscribe to products, projects, services, or communications from us or our affiliates.

Opt-Out

If You no longer wish to receive direct marketing materials from us, You may opt out by using the unsubscribe link in our emails or by contacting us at [email protected].

To find out more about CASL, please visit the official Government of Canada website at fightspam.gc.ca.

PART D — CONTACT, PRIVACY REQUESTS, AND COMPLAINTS

We welcome Your questions, comments, requests, and complaints regarding this Privacy Policy and our privacy practices. Please contact us at:

Privacy Officer, ASPAC Developments Ltd.
[email protected]