PURPOSE:

Wajax is committed to compliance with Canada’s Anti-Spam Law (CASL). We take important steps to ensure our customers and others who receive communications from us do not encounter spam in violation of CASL. We only send commercial electronic messages (CEMs) in compliance with this CASL Compliance Policy and our related internal procedures that address CASL obligations.

WHAT IS SPAM?

Spam is unsolicited electronic messages, also known as “junk” e-mail or text messages, often, but not always, sent in bulk form. An electronic message may be spam if:

(1) The message is deceptive in that there is an attempt to hide the true sender or content of the message;

(2) The recipient’s personal identity and context are irrelevant because the message is equally applicable to any other potential recipient; or

(3) The recipient has not granted express or implied consent for the message to be sent.

WHAT IS A COMMERCIAL ELECTRONIC MESSAGE?

A CEM is any electronic message that encourages participation in a commercial activity, regardless of whether there is an expectation of a profit.

Wajax only sends CEMs from our servers in compliance with this CASL Compliance Policy.

Generally, the sender of a CEM needs to obtain express or implied consent from the recipient before sending the message, as outlined in s. 1.1 of this Policy. The CEM must include information that identifies the sender, provides the sender’s contact information and enables the recipient to withdraw consent.

POLICY STATEMENTS:

1. SENDING COMMERCIAL ELECTRONIC MESSAGES

1.1 Wajax only sends CEMs in the following contexts:

· when the individual has explicitly provided their consent to receive such messages either verbally or in writing;

· when the message is in response to a request for information or an inquiry;

· when the message communicates factual information regarding a customer’s account or contractual relationship with Wajax;

· when the message facilitates, completes or confirms an agreed upon transaction;

· when the receiver of the message has voluntarily disclosed their e-mail contact or conspicuously published their e-mail contact without indicating that they do not want to receive CEMs;

· when communicating with a referral;

· to satisfy or enforce a legal obligation or right; or

· when consent to receive the message can be implied through an existing business relationship (i.e. the customer has purchased a product or service from Wajax within the past two years, or has an existing rental agreement in place with Wajax or one that expired less than two years ago).

1.2 All CEMs sent by Wajax outline a mechanism to opt out of receiving further promotional messages from Wajax or contain an unsubscribe link. When a message recipient unsubscribes from receiving further CEMs from Wajax, such a request will be processed as soon as possible, and no later than 10 business days after consent has been withdrawn.

1.3 There are limited contexts in which you cannot request that Wajax stop sending you messages, such as when we must communicate with you to enforce Wajax’s legal rights.

2. PROTECTING YOU FROM SPAM AND THE ALTERING OF TRANSMISSION DATA:

CEMs sent, or caused to be sent, from Wajax’s servers do not:

· Use or contain invalid or forged headers or non-existent domain names;

· Employ any technique to otherwise misrepresent or obscure the sender of an electronic message, the point of origin or the transmission path for the message;

· Cause delivery of a message to a destination other than, or in addition to, that specified by the sender due to the alteration of transmission data;

· Contain false or misleading information in the subject line or otherwise contain false or misleading content;

· Use a third party’s Internet domain name, or relay from or through a third party’s equipment, without permission of the third party; or

· Attempt to surprise or confuse you. Wajax makes every effort to ensure that you have either specifically asked to receive electronic messages from us, or you can reasonably expect to.

Wajax does not sell or exchange any of your information without your consent.

3. RESPONSIBILITY FOR COMPLIANCE WITH THIS POLICY

The Director of Marketing is responsible for periodically reviewing, approving and maintaining the Wajax CASL Compliance Policy and Procedures, as well as ensuring spot checks of CEM activity are conducted to ensure continued adherence to this Policy.

Directors of Sales are responsible for ensuring that this Policy and related procedures are communicated to and understood by all sales representatives. All Wajax employees are responsible for complying with Policy in their day-to-day business activities.

4. CONTACTING US WITH A SPAM COMPLAINT

If you receive an electronic message from Wajax that you believe violates this policy, please contact us as follows: E-mail: CASL@wajax.com

All Wajax staff are aware of this CASL Compliance Policy, are appropriately trained and are required to ensure that CEMs are sent in accordance with this Policy and related procedures.