PRIVACY POLICY

We are Avalon Advanced Materials (“Avalon”), and we are committed to respecting and preserving the privacy of all those with whom we interact, and who access and use our website https://avalonadvancedmaterials.com/ (the “Site”) including any content, documentation, and functionality offered thereon (collectively, the “Services”). This privacy policy (the “Privacy Policy”) describes how we collect, use, and disclose personal information. By accessing or using the Site or our Services, you agree that you have read, understood, and agreed to be bound by this Privacy Policy. If you do not accept the terms of this Privacy Policy, you may not access or use the Services.

As part of our regular review of all our policies and procedures, we may change this Privacy Policy from time to time without notice to you. The date on which this Privacy Policy was last updated will appear at the top of this page. You should periodically review this Privacy Policy so that you are aware of any changes which might affect you. Please also carefully read our Legal Disclaimer found at https://avalonadvancedmaterials.com/legal/.

Collection of your Personal Information

For the purposes of this Privacy Policy, personal information (“Personal Information”) means any information about an identifiable individual, or information that when combined with other, readily available information, may be used to identify an individual. Personal Information excludes anonymous or de-identified data that is not associated with a particular individual (“Non-identifiable Information”).

What Personal Information do we collect?

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

• Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, e-mail address, IP address, shareholder status, factors influencing your investment decisions, and how you discovered us (for example, when you select the “contact us” feature on the Site and submit a message to us or sign up for our newsletter).
• Non-identifiable Information, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific part of our Site.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.
• Non-personal details about your Site interactions, including the full URLs, clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.

How do we collect Personal Information?

We only collect Personal Information that we believe is reasonably necessary for a legitimate purpose, as further described below. We use different methods to collect your Personal Information, including through:

• Direct interactions with you when you provide it to us, such as when you contact us through the Site.
• Automated technologies or interactions as you navigate our Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies or other tracking technologies.
• Third parties or publicly available sources, such as our business partners, and unaffiliated third parties.

Cookies

We use cookies and similar tracking technologies to track the activity on our Site and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Use of Your Personal Information

We will only use your Personal Information for purposes identified in this Privacy Policy or if required by law. The Personal Information that we collect and store is primarily used for the following purposes:

1. to provide you with access to the Site or to facilitate provision of any Services to you;
2. to provide you with information relating to Avalon, notify you about changes to our Site or to any Services we provide;
3. to provide you with information that you request from us;
4. to follow up on your comments and suggestions;
5. to fulfil 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;
6. to carry out our obligations and enforce our rights arising from any contracts with you;
7. to improve our Site or services and for marketing purposes;
8. to manage and develop our business systems and operations; 
9. to monitor and conduct an analysis of our website traffic and usage patterns; 
10. to protect our rights and property; and
11. to lessen a serious threat to personal safety, health or security.

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?hl=en

 

Disclosure of your Personal Information

We will not sell, share, trade or otherwise distribute your Personal Information to third parties, except in accordance with this Privacy Policy. 

We may share Personal Information collected from you with our affiliates, or in the context of a business transaction, we may transfer such Information to a successor entity or to an entity which purchases substantially all of the assets of Avalon.

We sometimes contract with outside organizations to perform specialized services such as hosting the Site. Our suppliers may at times receive, process or handle some of your Personal Information. Only the Personal Information necessary to perform the services under the contract is given to the supplier. Under their contracts with us, our suppliers may use such Personal Information only to carry out the contracted service and must not store or use the information for any other purpose. Our contracts with suppliers require that they provide a level of protection for your Personal Information that is comparable to our own.

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 other agreements to which we are a party, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Avalon, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Transfers

Note that Personal information may be stored, accessed, used and otherwise processed inside and outside of Quebec and/or Canada. When Personal Information is located outside Quebec and/or Canada, it may be subject to laws that have different standards of protection and may allow for foreign law enforcement and governmental access. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

Security 

The security of your Personal Information is important to us. To ensure that your Personal Information is secure, we have put in place commercially suitable procedures to safeguard the Personal Information we collect against unauthorized use, disclosure, or modification. Nonetheless, transmission of information on the internet is not completely secure. Therefore, we cannot guarantee the security of data sent to us electronically through the Site, by email or otherwise and transmission of such data is therefore entirely at your own risk. Likewise, the storage of information is not completely secure and we cannot guarantee the security of data stored on our system and storage of such data is therefore entirely at your own risk.

Links To Other Sites

Our Site may contain links to other sites that are not operated by Avalon. 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.

Children’s Privacy

Our Site is not meant for or targeted at anyone under the age of 18 (“children”). We do not knowingly collect Personal Information from children. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental or guardian consent, we take steps to remove that information from our servers.

Retention of Personal Information 

The Personal Information that you provide will be retained by Avalon in accordance with applicable laws. However, we will take reasonable steps to destroy or permanently de-identify Personal Information we hold if it is no longer needed for the purposes for which it was collected.

Access and Correction

Avalon will take reasonable steps to ensure the Personal Information we hold is accurate, complete and up-to-date. Upon your written request, and subject to certain exceptions provided by law, Avalon will inform you of the existence, use, and disclosure of your Personal Information and give you access to that information. Avalon may charge a minimal fee for providing such access to you. If you believe that the Personal Information that Avalon holds about you is not accurate or complete, you may write to Avalon at the email ir@avalonam.com.If you are able to establish that the information is not accurate or complete, Avalon will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. In order to facilitate a request to correct or update information, Avalon may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by Avalon.

If you are a resident of Quebec, we will inform you if we exclusively use automated processing to render a decision about you. You also have the right to request information about the Personal Information used to make that decision, and to request that the information be corrected.

Canada’s Anti Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

Consent and Withdrawing your Consent

By submitting Personal Information to Avalon, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your Personal Information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your Personal Information time by contacting us at ir@avalonam.com.If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

Contact Us

If you have any questions, concerns or suggestions regarding this Privacy Policy, please contact our Privacy Officer at: 416-364-4938, or privacy@avalonam.com, or writing us at:

Avalon Advanced Materials Inc., Attn: Privacy Officer, 2060 – 130 Adelaide St. West, Toronto, ON M5H 3P5