Privacy Policy - GT Group

1.Commitment to Privacy

GT GROUP (the “Company”) operates marine container transportation and container terminal services. Due to the security-sensitive and regulated nature of these activities, certain personal information must be collected and processed.

We are committed to protecting this information in accordance with applicable laws. To this end, GT GROUP has adopted this Privacy Policy (the “Policy”). This Policy sets out GT GROUP’s practices regarding the collection, use, and disclosure of your personal information and applies to the situations described in Section 3. This Policy does not apply to personal information obtained and processed in the context of employment with GT GROUP.

2.Applicable Legal Framework

The Company complies with:

The Personal Information Protection and Electronic Documents Act (PIPEDA);
The Marine Transportation Security Regulations;
The requirements of Transport Canada and port authorities;
The regulatory obligations of the Canada Border Services Agency (CBSA).

3.Personal Information Collected

How we process your personal information will depend on the nature of your interaction with us on our website and when you visit our container depot. Below is a description of how GT GROUP collects and uses your personal information, provided that we may also process your personal information as required by applicable laws or otherwise with your consent.

When you browse our website or visit our container depot, we process your personal information as described in Sections 3.1 through 3.5:

3.1 – When you submit your job application at GT GROUP;
3.2 – When you contact us using our contact and submission forms;
3.3 – When you request access to our customer portal;
3.4 – When you visit our container depot;
3.5 – When you request an activity receipt for external drivers.

3.1 When you submit your job application at GT GROUP

How do we collect your personal information?

We collect your personal information directly from you when you submit your job application at GT GROUP via our website, an external recruitment site, or through a recruitment agency.

What categories of personal information do we collect, and for what purposes do we use it?
Category of information	Use
Name and contact information	To communicate with you; To manage recruitment and employment; To manage health and safety; To ensure compliance with marine safety requirements; To ensure compliance with regulatory obligations.
Resume and employment history
Education and professional certifications
Work authorization status
Background checks and security clearances
Driving qualifications or professional credentials
References and interview notes
Information provided voluntarily

Who will have access to your personal information and to whom is it disclosed?

We restrict access to your personal information to employees who need such access as part of the recruitment process (human resources, internal team members related to the position to be filled, technical and administrative support). We use service providers that supply software and cloud-based services to collect, store, and process your personal information on our behalf (IT, payroll, recruitment, and professional consultants). When your application is submitted through a recruitment agency, your personal information is shared with a criminal background check service provider.

3.2 When you contact us using our contact and submission forms

How do we collect your personal information?

We collect your personal information directly from you when you fill out our contact or submission form on our website.

What categories of personal information do we collect, and for what purposes do we use it?
Category of information	Use
Last name, first name, email, phone number (if personal information is provided).	To verify your identity; To allow the relevant GT GROUP staff to contact you regarding a general inquiry or a quote request.
Message content / instructions (if personal information is provided).

Important: Please do not include any personal information that is not necessary for the content of the message. Note: Whenever possible, please provide us with your work contact information (email and phone number).

Who will have access to your personal information and to whom is it disclosed?

GT GROUP staff, as required by their duties, will have access to all or part of your personal information. Service providers necessary for the operation of our website.

3.3 When you request access to our customer portal

How do we collect your personal information?

We collect your personal information directly from you when you ask us to create a “Customer Portal” account for you.

What categories of personal information do we collect, and for what purposes do we use it?
Category of information	Use
Last name, first name, email	To allow you to access your inventory.
Username and password	To allow you to access your inventory.

Who will have access to your personal information and to whom is it disclosed?

GT GROUP staff, as required by their duties (technical support), will have access to all or part of your personal information. Service providers necessary for the operation of our website.

3.4 When you visit our container depot

How do we collect your personal information?

We collect your personal information directly from you when you fill out the vehicle entry and exit log during a visit to our container depot. When you visit our container depot, we use video surveillance cameras. The images captured may constitute personal information when they allow a person to be identified. Video recordings are retained for a limited period and secured in accordance with our privacy practices.

What categories of personal information do we collect, and for what purposes do we use it?
Category of information	Use
Vehicle entry and exit log
Identification data: last name, first name, phone number	To ensure compliance with port security requirements; To ensure compliance with marine security requirements; To control access to facilities; To ensure compliance with regulatory obligations; To monitor assets and operational efficiency.
Point of contact
Arrival and departure times
CCTV cameras
CCTV footage	To control access to facilities; To ensure compliance with regulatory requirements; To ensure the safety of the premises, our employees, customers, and visitors.

Who will have access to your personal information and to whom is it disclosed?

GT GROUP staff, as required by their duties, will have access to all or part of your personal information and video recordings. We may share your personal information with certain entities, including port authorities, Transport Canada, the CBSA, and any other government authority when required by law or circumstances.

3.5 When you request an activity receipt for external drivers

How do we collect your personal information?

We collect your personal information directly from you when you request an activity receipt for external drivers in order to issue the receipt.

What categories of personal information do we collect, and for what purposes do we use it?
Category of information	Use
Identification data: last name, first name, phone number	To control access to facilities; To enable the sending of a transaction receipt; To ensure compliance with regulatory requirements.
License plate number

Who will have access to your personal information and to whom is it disclosed?

GT GROUP staff, as required by their duties, will have access to all or part of your personal information. We may share your personal information with certain entities, including port authorities, Transport Canada, the CBSA, and any other government authority when required by law or circumstances.

4.Consent

By accepting our Policy or providing us with personal information after having had the opportunity to review it, you agree that your personal information will be processed in accordance with our Policy, subject to legal requirements.

5.Transfer Outside Quebec or Canada

Personal information may be processed outside of Quebec or Canada. Appropriate safeguards are in place in accordance with applicable laws.

6.Retention of Information

Personal information is retained only for as long as necessary to fulfill operational, legal, and regulatory obligations.

7.Safeguards

The Company maintains appropriate safeguards, including:

Controlled facility access;
Secure IT infrastructure;
Staff training;
Encryption and monitoring systems;
Restricted access to personal information.

8.Individual Rights

Any individual may:

Request access to their personal information;
Request the correction of any incomplete or inaccurate personal information;
Obtain information about our practices;
Withdraw consent for the disclosure or use of the personal information we hold about them;
File a complaint with the Office of the Privacy Commissioner of Canada. However, we encourage you to contact our Privacy Officer first.

Requests must be sent to the Privacy Officer using the contact information provided in Section 10 of this Policy.

9.Cookies

Our website uses cookies to remember your browsing preferences. You can change these preferences at any time in your browser settings.

We also use Google Analytics to analyze the use of our site and improve your experience. This tool generates statistical reports that may include information such as your approximate location (country, city) as well as certain browsing data, collected via cookies.

In addition, we use Google Ads to track visitor interactions on our website and measure user actions, with the aim of optimizing our advertising campaigns.

While browsing, you have the option to enable or disable cookies, including those used for identification, profiling, or location purposes, via the cookie management banner displayed on our site.

10.Privacy Officer

For any request, question, or comment regarding this Policy, please contact:

Human Resources Department
rh@gtgroupinc.com

11.Changes

This Policy may be updated periodically. The most recent version will be posted on our website.