GVE ANTI-SPAM POLICY

1. PURPOSE AND SCOPE OF THIS POLICY

GlobalVision is committed to complying with Canada’s Anti-Spam Legislation and its relevant rules and regulations (hereinafter “CASL”). CASL regulates commercial electronic messages (“CEMs”), which are messages that encourage participation in a commercial activity. This GVE Anti-Spam Policy (hereinafter “Anti-Spam Policy”) is a formal statement of rights and obligations addressed to clients, partners, service providers, and potential clients (hereinafter “Outside Parties”) who may receive electronic communications from GlobalVision. The purpose of this Anti-Spam Policy is to provide transparency by informing Outside Parties of GlobalVision’s practices relating to electronic communications, the point of contact at GlobalVision for any concern pertaining to electronic communications, and the procedure to unsubscribe from CEMs received from GlobalVision. This Anti-Spam Policy applies to CEMs sent by GlobalVision from Canada or accessed in Canada by Outside Parties.

2. INITIATIVES TO COMPLY WITH CASL

GlobalVision has implemented various business procedures, processes and guidelines to ensure compliance with CASL. In addition to adopting this Anti-Spam Policy, GlobalVision has undertaken the following initiatives:

i. IMPLEMENTATION OF CASL COMPLIANT CONSENT COLLECTION PROCESSES

GlobalVision must obtain the consent of Outside Parties in order to send a CEM. This consent may be express or implied in certain circumstances, unless the electronic communication is specifically exempt from CASL’s consent requirements. GlobalVision has modified some of its consent collection processes to ensure that the express consent of recipients is obtained in compliance with CASL. GlobalVision has incorporated a clear “opt-in” mechanism on its website whereby Outside Parties can select a subscribe checkbox which communicates their request to receive CEMs from GlobalVision.

ii. CASL REQUIREMENTS FOR EMAIL FOOTERS

GlobalVision has revised its email footers to ensure compliance with CASL’s requirements. All CEMs sent by GlobalVision identify GlobalVision as the party sending the CEM, provide a method whereby the recipient can readily contact GlobalVision, such as a mailing address and a web address, and provide a working unsubscribe mechanism.

iii. UPDATE OF UNSUBSCRIBE MECHANISMS

GlobalVision has implemented changes in its processes to ensure that all CEMs provide a working unsubscribe mechanism that is functional for sixty (60) days and that allows for unsubscribe requests to be processed within a maximum of ten (10) business days. Recipients may unsubscribe from receiving CEMs from GlobalVision at any time by following the process that is outlined in the CEM, or by contacting info@globalvision.co. Nonetheless, a recipient who unsubscribes from receiving CEMs from GlobalVision may still receive electronic messages from GlobalVision which relate to an ongoing business relationship or which are exempt under CASL.

iv. IMPLEMENTATION OF INTERNAL GUIDELINES AND EMPLOYEE TRAINING

GlobalVision has implemented internal guidelines and an employee training program on CASL awareness. Such program requires employees to confirm their awareness of CASL requirements.

3. WHY ARE YOU RECEIVING AN ELECTRONIC MESSAGE FROM GLOBALVISION?

GlobalVision may send the following types of electronic messages from time to time:

  • – An electronic message sent to GlobalVision’s current or potential clients by GlobalVision’s marketing, sales or business development teams. Such electronic messages may be sent for prospecting purposes or to respond to a request for information or an inquiry;
  • – An electronic message sent to GlobalVision’s current clients, service providers, business partners, or other persons with whom GlobalVision has a business relationship in order to carry out its commercial activities;
  • – An electronic message sent to potential service providers by various GlobalVision business units as GlobalVision may outsource part of its activities to a third party;
  • – An electronic message sent to potential business partners;
  • – An electronic message sent to GlobalVision’s current or potential clients, service providers and business partners to provide information on GlobalVision projects and services. For example, GlobalVision may send newsletters or invitations to events in the context of a current or potential business relationship; or
  • – An electronic message sent by GlobalVision throughout its recruitment process. For example, GlobalVision’s HR department may contact potential candidates electronically for recruitment purposes.

If you have received a CEM or other electronic communication from GlobalVision, this may be for one of following reasons: (i) you have an existing business relationship with GlobalVision, (ii) you have provided your express or implied consent to receive CEMs from GlobalVision, or (iii) the electronic communication is exempt from CASL or its consent requirements.

4. WHEN IS A CEM SENT WITH YOUR CONSENT?

i. Express Consent

You may have provided your express consent to GlobalVision by subscribing to receive our newsletter or other CEMs. You may verify the status of your consent by sending an email to info@globalvision.co.

ii. Implied Consent

Your implied consent may be inferred in the following circumstances:

  • (a) GlobalVision has an existing business relationship with you or has a former business relationship with you which terminated less than two (2) years ago;
  • (b) GlobalVision received an inquiry from you within the last six (6) months; or
  • (c) You disclosed your electronic address to GlobalVision. For instance, you may have provided your business card to a GlobalVision employee or you may have disclosed your electronic address through GlobalVision’s website and the CEM sent is in connection with your business role and function.

GlobalVision is not required to obtain your consent in order to send you the following types of electronic messages:

  • An electronic message that is sent to you once as a result of a referral by a current GlobalVision client, service provider, business partner or employee who also has a personal or business relationship with you;
  • – An electronic message that contains a quote or an estimate pursuant to your request for a quote or estimate;
  • – An electronic message that facilitates, completes or confirms a transaction;
  • – An electronic message that provides warranty, product recall, safety or security information; or
  • – An electronic message that provides information regarding a GlobalVision product or service purchased (including updates and upgrades) or the ongoing use or purchase of a GlobalVision product or service.

5. WHEN IS AN ELECTRONIC MESSAGE EXEMPT FROM CASL REQUIREMENTS?

You may receive electronic messages from GlobalVision that are not considered as CEMs or that are otherwise exempt under CASL. An electronic message does not qualify as a CEM if it does not have the purpose of encouraging participation in a commercial activity. The following electronic messages are also exempt under CASL:

  • – An electronic message that you receive from a GlobalVision employee with whom you have a personal relationship such that you previously had a direct, voluntary, two-way communication with such employee;
  • – An electronic message that you receive from a GlobalVision employee with whom you have a family relationship;
  • – An electronic message sent internally within GlobalVision;
  • – An electronic message sent between GlobalVision and another business, if there is an ongoing business relationship between GlobalVision and such other business;
  • – An electronic message sent by GlobalVision in response to an inquiry or a request; or
  • – An electronic message sent by GlobalVision to enforce its legal rights or obligations.

6. CEM SENT IN CONNECTION WITH YOUR BUSINESS ROLE AND FUNCTION

If you receive a CEM from GlobalVision in the following circumstances, it would be considered as being sent in connection with your business role and function:

  • – An electronic message is sent to you by GlobalVision to sell its products and/or services because your business may be interested in the specific GlobalVision product or service promoted; or
  • – An electronic message is sent to you by GlobalVision in order to retain your services and is directly related to your business.

7. CEM RECEIVED THROUGH SOCIAL MEDIA

If you are connected on a social media network (e.g. LinkedIn) with a GlobalVision employee or if you have indicated that you are open to receiving messages about commercial activities, business opportunities or ventures, GlobalVision may contact you via such social media network. GlobalVision may also contact you if you have explicitly disclosed your electronic address on a social media website without an indication that you do not wish to receive CEMs and the CEM sent by GlobalVision is in connection with your business role and function.

8. WHAT TO DO IF YOU NO LONGER WISH TO RECEIVE CEMS FROM GLOBALVISION

You may unsubscribe from receiving CEMs from GlobalVision at any time by clicking on the unsubscribe link provided in the footer of the CEM. You may also send your unsubscribe request to us via email at info@globalvision.co, and we will ensure that you are removed from our list within ten (10) business days of your request. You may also contact us at info@globalvision.co if you have received a CEM from GlobalVision that you do not believe you should have received, and we will ensure that your email address is promptly removed from our list. Once you are unsubscribed, you will no longer receive CEMs from GlobalVision however, you may still receive electronic messages from GlobalVision which relate to an ongoing business relationship and/or which are exempt under CASL.

9. CHANGES TO THIS ANTI-SPAM POLICY

GlobalVision may review and update this Anti-Spam Policy from time to time based on changes in the applicable laws, rules and regulations, new technologies and standards, our business practices and Outside Parties’ concerns. All changes to this Anti-Spam Policy will be posted on this page and, if the changes are significant, GlobalVision will notify you of such changes by email or through a notice posted on our website. The date of the last update of this Anti-Spam Policy will be indicated to allow you to know when it was changed. GlobalVision will also archive all prior versions of this Anti-Spam Policy for your future reference or review.

10. QUESTIONS OR CONCERNS ABOUT THIS ANTI-SPAM POLICY

GlobalVision has a designated CASL Compliance Office to answer any question or concern. You may contact our CASL Compliance Office by emailing info@globalvision.co.