Fullarton Group Inc. — Website Policies

Effective date: November 1, 2026

Fullarton Group Inc. (“Fullarton Group,” “we,” “us,” or “our”) is a North American membership buying group for the promotional products industry. We respect your privacy and are committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose and safeguard personal information through our website at https://fullartongroup.com (the “Website”), our member login area, and our related communications and services (together, the “Services”).

We comply with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and other applicable privacy laws. By using the Services, you consent to the practices described in this Privacy Policy.

1. Information We Collect

Information you give us. When you complete a contact or inquiry form, apply for membership, register for an event, log in to the member area, or otherwise communicate with us, we may collect:

• Contact details, such as your full name, company name, job title, business email address, phone number and mailing address;
• Membership information, such as whether you are a distributor member or vendor partner, and information about your business needed to administer membership, group buying and rebate programs;
• Login credentials for the member area;
• Any other information you choose to include in messages or forms you send us.

Information collected automatically. When you visit the Website, we and our service providers may automatically collect technical information such as your IP address, browser type, device type, operating system, referring website, pages viewed, and the date and time of your visit. This information is collected through cookies and similar technologies, as described in our Cookie Policy.

Information from third parties. We may receive information about you from our members, vendor partners, event partners, or publicly available business sources (such as LinkedIn or company websites) where permitted by law.

Most of the information we collect is business contact information. We do not knowingly collect sensitive personal information, such as health or financial account information, through the Website.

2. How We Use Your Information

We use personal information for the following purposes:

• To respond to your inquiries and requests;
• To evaluate membership applications and administer memberships, group buying programs, rebate programs and member events;
• To provide and secure the member login area;
• To send you information about our programs, events and industry news, where you have consented to receive it;
• To operate, maintain, analyze and improve the Website and our Services;
• To protect the security and integrity of the Website and prevent fraud or misuse;
• To comply with legal, regulatory, accounting and contractual obligations; and
• For any other purpose we identify to you at the time of collection, with your consent.

We will not use or disclose your personal information for purposes other than those identified without first obtaining your consent, unless permitted or required by law.

3. Consent

We collect, use and disclose personal information with your consent, except where otherwise permitted or required by law. Depending on the circumstances, consent may be express (for example, ticking a box) or implied (for example, providing your contact details in a form so we can respond to you). You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the details below. Withdrawing consent may affect our ability to provide certain Services, such as membership.

4. Electronic Communications (CASL)

We send commercial electronic messages only in accordance with Canada’s Anti-Spam Legislation (CASL) and, where applicable, the U.S. CAN-SPAM Act. Every marketing email we send identifies Fullarton Group and includes an easy way to unsubscribe. You may unsubscribe at any time by clicking the unsubscribe link in any email or by contacting us. We will process your request within 10 business days. Even if you unsubscribe from marketing messages, we may still send you transactional or membership-related messages.

5. How We Share Your Information

We do not sell or rent your personal information. We may share personal information only as follows:

• Service providers who perform services on our behalf, such as website hosting, IT support, email delivery, event management and analytics. They are contractually required to protect your information and use it only to provide services to us;
• Vendor partners and members where necessary to administer group buying and rebate programs or member events in which you participate, and only to the extent required for that purpose;
• Business transfers in connection with a merger, acquisition, financing or sale of all or part of our business, subject to appropriate confidentiality protections;
• Legal requirements, when required or permitted by law, such as in response to a court order, subpoena or lawful request by public authorities, or to protect our rights, property or safety, or that of others.

6. Storage and International Transfers

Our records are stored in Canada and may also be stored or processed in the United States or other countries by our service providers. When information is stored outside Canada, it is subject to the laws of that jurisdiction and may be accessible to courts, law enforcement and national security authorities there. We use contractual and other measures to require a comparable level of protection.

7. Retention

We keep personal information only as long as necessary to fulfil the purposes for which it was collected, or as required by law (for example, tax and accounting requirements). When information is no longer required, we securely destroy, erase or anonymize it.

8. Safeguards

We use reasonable physical, administrative and technical safeguards appropriate to the sensitivity of the information to protect it against loss, theft, and unauthorized access, use, disclosure, copying or modification. These include encryption in transit (SSL/TLS), access controls and limiting access to staff who need the information to do their jobs. No method of transmission over the internet is completely secure, so we cannot guarantee absolute security. If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

9. Your Rights

Subject to applicable law, you have the right to:

• Request access to the personal information we hold about you;
• Ask us to correct personal information that is inaccurate or incomplete;
• Withdraw your consent to certain uses of your information; and
• Ask us to delete your information, where we are not required to retain it.

To make a request, contact our Privacy Officer using the details below. We may need to verify your identity before responding. We will respond within 30 days, or as otherwise permitted by law. If we cannot provide access to certain information, we will explain why, subject to any legal restrictions.

10. Children

The Services are intended for businesses and professionals. They are not directed to children under 16, and we do not knowingly collect personal information from children.

11. Third-Party Links

The Website may contain links to third-party websites and social media platforms, such as Facebook and LinkedIn. We are not responsible for the privacy practices or content of those sites. Please review their privacy policies before providing them with any information.

12. Additional Information for U.S. Visitors

(a) Do Not Track and Global Privacy Control. Some browsers send “Do Not Track” (DNT) signals. Because there is no common industry standard for DNT, the Website does not currently respond to DNT signals. Where required by applicable law, we treat a Global Privacy Control (GPC) signal as a valid request to opt out of the sale or sharing of personal information for that browser.

(b) Third-party tracking. Third parties, such as analytics providers, may collect information about your online activities over time and across different websites when you use the Website, as described in our Cookie Policy. We do not allow third parties to use the Website to serve targeted advertising.

(c) California residents (California Consumer Privacy Act). This section applies to residents of California and supplements the rest of this Privacy Policy. In the past 12 months, we have collected the following categories of personal information: identifiers (such as name, email address, phone number, IP address and account login); professional or employment-related information (such as company name and job title); commercial information (such as membership and program participation); and internet or other electronic network activity (such as browsing information on the Website). We collect this information from the sources described in Section 1, for the business purposes described in Section 2, and disclose it to the categories of recipients described in Section 5. We retain each category for the periods described in Section 7.

We do not sell personal information and do not share it for cross-context behavioural advertising, and we have not done so in the past 12 months. We do not knowingly sell or share the personal information of consumers under 16. We do not use or disclose sensitive personal information for purposes that would require offering a right to limit its use.

Subject to certain exceptions, California residents have the right to:

• Know what personal information we have collected about them, including the categories and specific pieces of information, the sources, the purposes, and the categories of third parties to whom it was disclosed;
• Request deletion of their personal information;
• Request correction of inaccurate personal information;
• Opt out of the sale or sharing of personal information (although we do not sell or share it); and
• Not be discriminated against for exercising any of these rights.

To exercise these rights, call us toll-free at (888) 255-4164 or email kaddis@fullartongroup.com. We will verify your request by matching information you provide with information we hold. You may use an authorized agent to submit a request on your behalf; we may require proof of the agent’s authority and verification of your identity. We will confirm receipt within 10 business days and respond within 45 days, which may be extended by a further 45 days where permitted by law.

(d) Other U.S. states. Residents of other U.S. states with consumer privacy laws may have similar rights, depending on their state’s law. To make a request, contact us using the details below. If we deny your request, you may appeal by replying to our decision with the subject line “Privacy Request Appeal,” and we will respond within the time required by law.

13. Additional Information for Quebec Residents

This section applies to residents of Quebec and supplements the rest of this Privacy Policy, in accordance with the Act respecting the protection of personal information in the private sector (Quebec), as amended by Law 25.

• Person in charge of the protection of personal information: Keith Addis, President & Owner, who can be reached at kaddis@fullartongroup.com or at the address in Section 15.
• Tracking technologies: Cookies and similar technologies that can identify, locate or profile you are disabled by default. They are only activated if you consent to them.
• Additional rights: In addition to the rights in Section 9, you may ask us to provide computerized personal information you gave us in a structured, commonly used technological format (data portability, where applicable), and to stop disseminating your personal information or de-index any hyperlink attached to your name, where permitted by law.
• Automated decisions: We do not make decisions about you based exclusively on automated processing of your personal information.
• Transfers outside Quebec: Before communicating personal information outside Quebec, we assess whether it will receive adequate protection, including through a privacy impact assessment where required by law.
• Response time and complaints: We will respond to written requests within 30 days. If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca).

14. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised effective date. If we make material changes, we will provide notice on the Website or by other appropriate means.

15. Contact Us

If you have questions, concerns or requests about this Privacy Policy or our handling of your personal information, please contact:

Fullarton Group Inc.

Attn: Keith Addis

148 Fullarton St., Suite 400, London, ON N6A 5P3, Canada

Phone: (888) 255-4164

Email: kaddis@fullartongroup.com

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or 1-800-282-1376.