Global Privacy Policy

American Industrial Transport, Inc.

__________________________________________________________________________________________

Effective Date: July 15, 2026

Policy Scope

This Privacy Policy applies to American Industrial Transport, Inc and its U.S. subsidiaries (collectively, “AITX”, “we”, “us”, or “our”). It describes our data and privacy practices and applies to the Personally Identifiable Information (PII) that we collect, use, and disclose. This Privacy Policy applies to all current and former customers, business partners, prospective business customers, applicants, and vendors who communicate or otherwise interact or engage with us regarding products, services, or employment offered by AITX. This Privacy Policy does not apply to personal information collected from or about any of our current or former employees. PII collected from any such employees are governed by our employment policies and described in the employee handbook.

AITX respects your privacy, and we will do our best to earn and keep your trust. This Privacy Policy applies to the privacy practices of AITX and identifies the personal information we collect and how this data will be used, disclosed, and protected. By accessing, using, submitting data to, or otherwise interacting with the Site or providing information to us, you consent to the data practices described in this Privacy Policy. We recommend that you review this Privacy Policy in its entirety and make the determination if you want to continue using this Site. If you do not agree to the terms of this Privacy Policy, please do not use the Site or provide personal information to us.

Collection of Personal Information

AITX collects information, including personal information, that you provide us. References to personal information shall be deemed to include personal data as defined by GDPR, personal information as defined by CCPA, and “personal data” or similar term as defined in other U.S. state privacy laws. AITX may collect information actively or passively. Active collection means information that you provide directly on the website. Passive collection means information that is collected automatically via cookies or web beacons. See the Cookie Policy section of this notice for more information.

Note that we may de-identify personal information by removing characteristics that make the data personally identifiable to you. We will treat de-identified data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, we will treat the combined information as personal information under this Privacy Policy.

Personal Information collected actively may include:

First Name
Middle Name
Last Name
Email Address
Street Address
City
State
Postal Code
Phone Number
Social Security Number
Date of Birth
Driver’s License Number
Job Title
Financial Information
Education Information
Work History

Personal Information collected passively may include:

IP address
Device identifier or other unique identifier
Browser type
Service provider
Page visits
Length of visit
Referral URL
Website preferences

Use of Personal Information

AITX may use the personal information we collect for one or more of the following purposes:

To conduct business with you
To improve our service offerings
To improve your experience with us
To process registrations submitted through the Site
To process lease and repair agreements
To process payments
To improve the content, functionality, usability, and security of the Site
To understand how you use the Site
To provide effective customer support
To respond to inquiries and complaints
To provide requested information
To prevent or detect fraud
To personalize your experience when interacting with us
To help you receive email, direct mail, and SMS text messages
To send marketing messages and engage in advertising activities
To comply with legal requirements and assist in dispute resolution
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements
To administer surveys or questionnaires
To conduct financial, tax, and accounting audits
To conduct security, privacy, risk, and compliance audits
To conduct analytical research
To carry out business transactions, such as in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including due diligence
To permit you to apply for employment
To carry out any other purpose disclosed at the time of collection or otherwise consented to at the time of collection

Disclosure of Personal Information

We may share the data we have collected about you (including personal information) in the circumstances described below or elsewhere in the Privacy Policy, as disclosed at the time you provide information, or otherwise with your consent.

AITX employs third party companies and people (“Agents”) to perform tasks on our behalf and may disclose Personal Information to them to provide products and services. These Agents provide services necessary to run our business and may include:

Technology services
Financial and billing services
Payment processing services
Analytics services
Advertising and marketing services
Employment and recruiting services
Regulatory and compliance services
Other similar services

AITX also may share Personal Information with our parent company, ITE Management, its subsidiaries, and other affiliated entities for the purposes identified in the Use of Personal Information section of this policy.

Retention of Personal Information

We retain your personal information for as long as reasonably necessary to carry out the purposes for which it was collected, allow you to exercise the choices and rights you requested, comply with our contractual obligations, enforce our policies, or as required by applicable laws or regulations. Different types of personal information may need to be retained for different periods of time depending on the purposes for which the data is processed and any regulatory retention requirements for certain categories of data. The determination of retention periods is based on criteria including:

The purposes for which it is processed
The legal basis for processing
Legal requirements for retention (i.e. employment, health, and safety law)
Regulatory requirements.

Your Choices

As provided by applicable law, you may have the right to access, correct, or delete any Personal Information we hold about you. AITX will respond to reasonable requests in an appropriate timeframe as determined by the respective governing authority. See the State and Country Specific Information section of this policy for more information.

Information Security

AITX utilizes commercially reasonable and appropriate technical, physical, and administrative security controls designed to help protect against unauthorized or unlawful processing, loss, destruction, damage, misuse, and alteration, considering the risks involved in the processing and the nature of the personal information. However, no data transmission over the internet, wireless transmission, or electronic storage can be guaranteed 100% secure. AITX cannot ensure or warrant the security of any data we collect. You use the Site and provide your data at your own risk.

Children’s Privacy

AITX offers railcar leasing and repair services to other businesses. The Site is general audience and is not intended for and does not target children under the age of 16. As such, we do not knowingly collect personal information directly from anyone under the age of 16. If you are under 16 years of age, do not provide any information on this Site, use any interactive or public comment features, or provide any information about yourself to us, including name, address, telephone number, email address, screen name, or username.

If we become aware that we have collected or received personal information from individuals under 16 years of age, we will make reasonable efforts to immediately delete that information. If you believe that we might have any information from an individual under 16, please contact us at [email protected].

AITX or our third-party business partners may collect data passively from you using cookies. A cookie is a small text file that writes to and stores information on your device when it is used to visit the Site. These cookies may be used by us or third parties to personalize content, deliver advertisements, and analyze traffic on this Site. You may be able to adjust your web browser so that your computer can disable, decline, block, or otherwise limit or clear cookies. For more information about how to manage cookies, please follow the instructions provided by your browser. For more information about cookies, please visit https://www.aboutcookies.org.

Applicable law states that AITX can store cookies on your device if they are strictly necessary for the operation of the Site. For all other types of cookies, we need a lawful basis for processing, which may include your permission. By agreeing to the use of cookies on our website, you are directing us to disclose your personal information to our third-party service providers for these purposes. The cookies used on this Site include:

Non-Discrimination

AITX will not discriminate against you for exercising your rights under any applicable privacy regulation.

Changes to Privacy Policy

We may amend this Privacy Policy at any time. If we make changes in the way we collect, use, and/or share your Personal Information, we will notify you by sending an email at the last email address that you provided to us, or by prominently posting notice of the changes on this Site. Should an amendment to this Privacy Policy be necessary, a new Effective Date will be displayed at the top of this notice.

State and Country Specific Information

California

We will only use your Personal Information for the purposes intended and as detailed in the Privacy Policy unless we have obtained your consent to use it for other purposes. If you have any concerns about how your Personal Information is handled, please reach out to us via one of the methods in the How to Contact Us section of this policy.

Personal Information We Collect

In the preceding twelve (12) months, AITX has collected, used, disclosed, sold, or shared the following categories of Personal Information set forth below for a variety of business purposes as described in the Use of Your Data section of this policy:

Category A: Identifiers
Category B: California customer records personal information categories
Category D: Commercial information
Category F: Internet or other electronic network activity information
Category I: Professional or employment-related information
Category K: Inferences drawn from other personal information

Rights of California Data Subjects

If you are a resident of California, you have certain rights under the CCPA, as amended by the California Privacy Rights Act (“CPRA”), relating to the Personal Information collected by AITX. These rights include:

Right to Access: You have the right to know what Personal Information AITX has collected about you and to request to access specific pieces of Personal Information AITX has collected about you.
Right to Correct: You have the right to request that we correct inaccurate personal information we hold about you.
Right to Delete: You have the right to request that we delete the Personal Information we have collected from you.
Right to Opt-out of the Sale or Sharing for Cross-Context Behavioral Advertising
Right to Not Be Discriminated Against: You have the right to not be discriminated against for exercising any of the aforementioned rights.

To exercise the rights listed above, you must submit a verifiable data privacy request via one of the methods listed in the How to Contact Us section of this policy.

Verifying Your Request

To submit a verifiable request, you will be sked to provide certain information to help us verify your identity. The information we ask may differ depending on the type of request as well as the type, sensitivity, and value of the personal information that is subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion. We may also require that you provide a written declaration that you are who you say you are.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Sales and Sharing of Personal Information

AITX does not sell personal information to third parties for monetary consideration. However, the collection of data on our behalf by certain of our third-party Site analytics or digital advertising service providers may be considered a “sale” and considered “sharing” under the CPRA. To disable sharing through cookies set by third parties that may be considered “sales” or “sharing” under CCPA and CPRA, click the ‘Cookie Preferences’ link in the footer of this Site. In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies https://www.privacyrights.info/.

Collection, Use, and Processing of Sensitive Personal Information

Under the CPRA regulation, a business must only provide the Right to Limit the Use and Disclosure of Sensitive Personal Information when such use is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. AITX does not use or disclose Sensitive Personal Information for such purposes and/or its uses fall with the statutory exceptions, and we therefore do not offer this right at this time.

Do Not Track

Some web browsers may transmit “Do Not Track” signals to indicate that you do not want your website visit information collected. Because there is not yet an accepted standard for how to respond to DNT signals, this website does not respond to such signals. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Complaints

For California consumers, if AITX was unable to resolve your data privacy request, you have the right to lodge a complaint with the California Privacy Protection Agency (CPPA) at the following website: https://www.cppa.ca.gov/webapplications/complaint. AITX is committed to working with you to obtain fair resolution of any complaint or concern about privacy.

Canada

We make reasonable efforts to notify you of the purposes for which your Personal Information will be used or disclosed and if the initial purpose changes. Please note, you may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice). If you have any concerns about how your Personal Information is handled, please reach out to us via one of the methods in the How to Contact Us section of this policy.

International Transfers

AITX is a U.S.-based company. By using our website or engaging with our services, you acknowledge and agree that your personal data may be transferred, stored, and processed in the United States as outlined in this policy. We take appropriate technical and administrative measures to safeguard your personal data and ensure it is treated in accordance with Canadian Federal and Provincial privacy laws and regulations. If you have any concerns about how your Personal Information is handled, please reach out to us via one of the methods in the How to Contact Us section of this policy.

Rights of Data Subjects

Subject to certain limits set out in applicable laws, you have certain rights relating to the Personal Information collected by AITX. These rights include:

Right to Access
Right to Correction
Right to Withdraw Consent

Canadian residents may have additional rights under Canadian law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and successor legislation. Please see the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca) for further information. To submit a data privacy request, please reach out to us via one of the methods in the How to Contact Us section of this policy. Your request much include your full name, street address, city, province, postal code, and an email address so that we are able to contact you regarding your request.

Complaints

For Canadian data subjects, if AITX was unable to resolve your data privacy request, you have the right to lodge a complaint with the Office of Privacy Commissioner of Canada (OPC) at the following website: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/. AITX is committed to working with you to obtain fair resolution of any complaint or concern about privacy.

Province-specific sites also exist for data subjects of the following Canadian provinces:

British Columbia: https://www.oipc.bc.ca/for-the-public/how-do-i-make-a-complaint/

Alberta: https://oipc.ab.ca/request-a-review-file-a-complaint/

Quebec: https://www.cai.gouv.qc.ca/en/complaints/

European Union and United Kingdom

Your Personal Information is protected in the EEA by the General Data Protection Regulation (GDPR) and in the United Kingdom by the GDPR (as it forms part of the law of England, Wales, Scotland, and Northern Ireland by virtue of Section 3 of the European Union (Withdrawal) Act 2018). If you have any concerns about how your Personal Information is handled, please reach out to us via one of the methods in the How to Contact Us section of this policy.

We process Personal Information for the purposes described in this Privacy Policy based on one or more of the following legal bases: (1) your consent; (2) performance of a contract with you; (3) compliance with legal obligations; and/or (4) as necessary for our legitimate business interests, provided such interests do not override your fundamental rights and freedoms related to data privacy.

International Transfers

AITX and its subsidiary AITX Railcar Services, LLC complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union (the “EU”) and the United Kingdom (the “UK”) to the United States (the “U.S.”) in reliance on EU-U.S. Data Privacy Framework. AITX has certified to the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles. If there is any conflict between the terms in the Privacy Policy and the EU-U.S. Data Privacy Framework Principles, the EU-U.S. Data Privacy Framework Principles shall govern.

To learn more about the EU-U.S. Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/. A list of companies that are currently certified under the EU-U.S. Data Privacy Framework is available at https://www.dataprivacyframework.gov/list.

If you are an EU or UK individual, where we transfer your personal data to third party service providers who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Rights of Data Subjects

You have certain rights under the GDPR, including the right to access a copy of your Personal Information that we are processing. In accordance with the GDPR, you have the following rights:

Right to Access: You have the right to request access to Personal Information we collected about you and information about its sources, purposes, and sharing.
Right to Rectification: You have the right to request that we correct the Personal Information we hold about you if it is inaccurate or incomplete.
Right to Withdraw Consent

In certain circumstances, you also have the following rights:

Right to Erasure (“Right to be Forgotten”): You have the right to request that erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated due to a legal obligation to retain it.
Right to the Restriction of Use of Your Personal Information: You have the right , in certain circumstances, to request that we limit our process of your Personal Information if you are contesting its accuracy; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or object to our processing.
Right to Object to Processing: You have the right to object to our processing of your Personal information for direct marketing (including profiling) or processing your personal data for purposes of scientific or historical research and statistics.
Right of Portability: You have the right, in certain circumstances, to request that we provide your Personal Information to you in a format that can be transferred to another entity.

In most cases, we will respond within one month. However, in accordance with applicable law, we may extend our response time for complex requests. To submit a data privacy request, please reach out to us via one of the methods in the How to Contact Us section of this policy.

Choice

We will provide an EU or UK individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected].

Government Access

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Automated Decision Making

We do not make decisions related to your Personal Information that are based solely on automated decision making (including profiling).

Complaints

AITX commits to resolve complaints concerning our collection or use of Personal Information received in reliance on the EU-U.S. DPF and the UK Extension of the EU-U.S. DPF. EU and UK individuals with inquiries or complaints regarding handling of Personal Information received in reliance on the EU-U.S. DPF and the UK Extension of the EU-U.S. DPF should first contact the Privacy Officer via one of the methods listed in the How to Contact Us section of this policy.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, AITX commits to refer unresolved complaints concerning our handling of Personal Information received in reliance on the EU-U.S. DPF and the UK Extension of the EU-U.S. DPF to BBB National Programs DPF Services, an alternative dispute resolution provider based in the United States. Please visit https://bbbprograms.org/programs/all-programs/dpf-consumers for more information or to file a complaint. This service is provided free of charge to you.

AITX is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”), and we are committed to responding promptly to inquiries and requests by the United States Department of Commerce for information relating to the EU-U.S. Data Privacy Framework Principles. Under certain conditions, individuals may invoke binding arbitration to address complaints regarding DPF compliance not resolved by other DPF mechanisms. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

How to Contact Us

Privacy Officer

American Industrial Transport, Inc.

100 Clark Street

St. Charles, MO 63301

[email protected]

1-866-211-3898

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