Purpose

Liftow Limited is committed to transparency and to complying with Canada’s Anti-Spam Legislation (CASL), which came into effect on July 1, 2014, as well as any other applicable laws, regulations and requirements.

This policy is a formal statement of the rights and obligations of Liftow Limited and the external parties with whom it communicates electronically. It is intended to inform external parties of the responsible and transparent practices adopted by Liftow Limited when sending commercial electronic messages.

The policy also provides information on how external parties may contact Liftow Limited with any concerns regarding electronic communications, as well as how they may unsubscribe from receiving commercial electronic messages. In addition, this document answers frequently asked questions about Liftow Limited’s electronic communication practices and its compliance with Canada’s Anti-Spam Legislation.

Application and Scope

This Anti-Spam Policy generally applies to any electronic communications sent by Liftow Limited to external parties. It is supported by a range of business procedures and policies designed to ensure that such communications comply with CASL. Liftow Limited’s electronic communications with external parties must comply with the rules established by CASL and enforced by the Canadian Radio-television and Telecommunications Commission (CRTC), the Competition Bureau and the Office of the Privacy Commissioner of Canada. CASL regulates commercial electronic messages (CEMs), which are messages that include, among their purposes, the encouragement of participation in a commercial activity.

What Liftow Limited Doing to Comply with CASL

Liftow Limited is undertaking various initiatives to ensure compliance with CASL. It has adopted this Anti-Spam Policy to provide transparency to external parties regarding the organization’s electronic communication practices and compliance with CASL. Liftow Limited has also implemented the following initiatives:

CASL-compliant consent forms

Consent from external parties is generally required before Liftow Limited can send CEMs. This consent must typically be express; however, in certain circumstances, consent may be implied, and some messages are specifically exempt from consent requirements. Liftow Limited has modified certain consent forms to ensure that express consent obtained from recipients complies with CASL.

External parties may unsubscribe from Liftow Limited’s communications at any time. However, even if an external party unsubscribes from receiving CEMs from Liftow Limited, they may still receive electronic messages related to an ongoing business relationship or other messages that are exempt from CASL’s consent requirements.

Email Footers

Liftow Limited has modified its email footers to manage CASL consent requirements. Under CASL, all CEMs must include certain prescribed content. For example, Liftow Limited must clearly identify itself as the party sending the CEM, provide a method by which the recipient can readily contact Liftow Limited, such as a mailing address and one of the following: a telephone number with active response or voicemail, an email address, or a web address. The message must also include a working unsubscribe mechanism. CASL-compliant email footers have been updated on all email communications sent from Liftow Limited to help ensure compliance with CASL.

Unsubscribe Mechanisms

Liftow Limited has incorporated unsubscribe mechanisms into its electronic communications to manage CASL consent requirements. Under CASL, CEMs must provide a working unsubscribe mechanism that remains functional for at least 60 days and is processed without delay, and in any event within a maximum of 10 business days. Liftow Limited has established a uniform process to ensure that all unsubscribe requests are processed in accordance with CASL. You may unsubscribe from receiving CEMs from Liftow Limited by following the process outlined in the electronic message you received. However, even if you unsubscribe from receiving CEMs from Liftow Limited, you may still receive electronic messages from Liftow Limited that relate to an ongoing business relationship or that are otherwise exempt from CASL.

Why Are You Receiving an Electronic Message from Liftow Limited?

The types of CEMs Liftow Limited may send from time to time:

• Liftow Limited may send CEMs to current and potential clients, whether individuals or businesses, through its Marketing Department or Sales team. For example, these messages may be sent for prospecting purposes or to respond to a request for information or an inquiry.
• Liftow Limited may also send CEMs to current and potential service providers through various business units. For example, Liftow Limited may outsource part of its activities to third parties, such as maintenance companies or translation service providers, or its Human Resources Department may contact potential employees electronically for recruitment purposes.
• Liftow Limited may also send CEMs to current and potential business partners. For example, Liftow Limited may have partnerships with recruitment agencies, preferred partners, and other business partners.

If you have received a CEM from Liftow Limited and you believe that you should not have received it, please assess whether you have provided express or implied consent to receive CEMs or whether an exemption applies.

Express consent: You can verify whether you have provided express consent to Liftow Limited or check the status of your consent by sending an email to preferences@liftow.com.

Implied consent: : Liftow Limited may have implied consent if:

• You have an ongoing business relationship or a former business relationship with Liftow Limited that terminated within the previous two years.
• You made an inquiry or request to Liftow Limited within the previous 6 months.
• You disclosed your electronic address to a Liftow Limited employee, for example, by providing a business card.
• You conspicuously published your electronic address, for example, on a corporate website or in a brochure, and the CEM is relevant to your business role or functions.

When Is an Electronic Message Exempt from CASL?

If you are receiving electronic communications from Liftow Limited, the message may be exempt from CASL. This may be the case if the message falls within one of the following circumstances:

• You have an existing personal relationship with the Liftow Limited employee who contacted you, meaning that you have previously engaged in direct, voluntary, two-way communication with them.
• You have a family relationship with the Liftow Limited employee who contacted you.
• The CEM is sent within Liftow Limited, between Liftow Limited employees.
• The CEM is sent between Liftow Limited and another organization with which Liftow Limited has an ongoing business relationship.
• The CEM was sent by Liftow Limited in response to your requestor inquiry.
• The CEM was sent by Liftow Limited to enforce a legal obligation or to fulfill or exercise rights under an existing contract with you, such as an outstanding debt or a contract that has been breached.

In certain situations, your consent is not required for certain types of messages. However, you may still unsubscribe from receiving CEMSs from Liftow Limited.

Liftow Limited may send you a CEM without obtaining consent where the message:

• Is sent once following a referral by a current Liftow Limited client, service provider, business partner or employee, provided the applicable CASL requirements are met.
• Relates solely to providing you with a requested quote or estimate.
• Facilitates, completes or confirms a transaction.
• Relates to a Liftow Limited warranty, product recall, safety or security information.
• Provides information about:
  • Your ongoing use of, purchases from, or relationship with Liftow Limited; or
  • A Liftow Limited product, good, or service that you have purchased, including updates, upgrades, or other related information.

If you receive a CEM from Liftow Limited and believe that you should not have received it, please contact us immediately at caslofficer@liftow.com. We will promptly review your request, and where applicable, remove your electronic address from our CEM distribution list within 10 business days.

Social Media

You may be contacted by a Liftow Limited employee through a social media platform, such as LinkedIn, if you are connected with the Liftow Limited employee on that social network or if you have indicated through your preference settings that you are open to receiving messages about new business opportunities. You may also be contacted if you have conspicuously published your electronic address on a social media website, have not indicated that you did not wish to receive CEMs, and the message is relevant to your business role and functions.

What to Do if You No Longer Wish to Receive CEMs from Liftow Limited

Liftow Limited takes its legal and regulatory obligations seriously. You may unsubscribe from receiving CEMs from Liftow Limited at any time by following the unsubscribe instructions included in the electronic message or by emailing unsubscribe@liftow.com. Liftow Limited will process your unsubscribe request without delay and within the time period required by CASL, which is no more than 10 business days.

Updates to the Anti-Spam Policy

Liftow Limited may review and update this Anti-Spam Policy from time to time to ensure it remains current with applicable laws and regulations, new technologies, industry standards, and business practices, as well as to address concerns of external parties. Any changes to this Anti-Spam Policy will be posted on this page. If the changes are significant, Liftow Limited will provide more prominent notice, including, where appropriate, notification by email. Liftow Limited will also retain previous versions of this Anti-Spam Policy in an archive for review.

Questions or Concerns About This Policy?

Liftow Limited has designated a CASL Compliance Officer who is responsible for overseeing compliance with this Anti-Spam Policy.

The CASL Compliance office may be contacted:

By phone: 905-677-3270
By e-mail: caslofficer@liftow.com

If you require further assistance, you may contact the Liftow Limited CASL Compliance Officer by mail at Liftow Limited, 1400 Courtneypark Drive E., Mississauga, Ontario, Attention: CASL Compliance Officer. Alternatively, you may submit your inquiry by email to caslofficer@liftow.com.

Revised September 2026