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Privacy Notice - Claims Portal

Last updated on March 6, 2026

Raymond Chabot Inc. ("RCI"), in its capacity as court-appointed monitor of Asbestos Corporation Limited ("ACL") in proceedings under the Companies' Creditors Arrangement Act (Canada) and chapter 15 of the U.S. Bankruptcy Code in the U.S. Bankruptcy Court for the Southern District of New York, together with Grant Thornton NYC as applicable for U.S. claim intake support (collectively, "we", "us" or "our"), provide this Privacy Notice in relation to personal information that we collect and process in connection with the claims process, including through the claims portal available at ACLClaims.com (the "Portal").

In this regard, this privacy notice (hereinafter the "Notice") aims to inform you of the personal information that we collect as well as how this same information is used, communicated, and saved by us.

The Notice is designed to comply with applicable laws regarding the protection of personal information. Because many claimants are U.S. residents, this Notice also describes certain U.S. state privacy rights that may apply to you, where relevant.

1. Personal Information Categories

In this Notice, "personal information" or "personal data" means all information about an individual that identifies that individual, directly or indirectly, that may include, but is not limited to:

  • your contact information (name, mailing address, email address, telephone number);
  • identity information (date of birth; Social Security Number and/or Social Insurance Number; other tax identifiers, where applicable);
  • claim information (details of alleged asbestos exposure, work history, employers, unions, locations and dates of exposure, lawsuits and trust claims);
  • medical and health-related information (diagnoses, treatment records, pathology/autopsy reports, imaging scans, physician statements) and other supporting documentation you choose to provide;
  • financial and economic loss information (claimed medical expenses, lost wages, pension or Social Security related information, and supporting records);
  • information about your legal representatives (law firm and attorney contact details; fee arrangement type, if you provide it);
  • communications with us (emails, calls, correspondence, portal messages) and records of those communications; and
  • technical and usage information when you use the Portal (IP address, device/browser information, timestamps, pages viewed, cookie identifiers and similar technologies).

We do not knowingly collect information from children or others under the age of 16. If you are under the age of 16, please do not provide us with personal information without the involvement of a parent or legal guardian. If a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

2. Collection of Personal Information

We may collect personal information directly from you when you submit a Proof of Claim, upload supporting documents, register for or use the Portal, communicate with us, or otherwise interact with the claims process.

We may also collect personal information indirectly from other sources, where permitted by law and as needed for the claims process, including:

  • your authorized representatives (e.g., attorneys, executors, guardians, or other agents acting on your behalf);
  • courts, monitorship records and other official records related to the insolvency proceedings;
  • medical providers or facilities, where you have provided the necessary authorization or where otherwise permitted by law;
  • workers' compensation boards, asbestos trusts, or other claims processes, where you have authorized such collection/verification or where otherwise permitted by law; and
  • other parties involved in the proceedings (e.g., ACL, General Dynamics, insurers), and their professional advisors, to the extent necessary to administer and evaluate claims.

3. Use of Personal Information

We use personal information only for purposes that are identified at the time of collection or otherwise permitted or required by applicable law, including to:

  • administer the claims bar date process and the Portal, including receiving, logging, and managing Proofs of Claim and supporting documentation;
  • evaluate, validate, and adjudicate claims (including verifying identity and supporting evidence, assessing eligibility, and communicating determinations);
  • communicate with you and/or your authorized representative about your claim and the claims process;
  • prevent, detect and investigate fraud, misuse, or security incidents; and protect the integrity of the claims process;
  • comply with court orders, legal obligations, and requests from courts, regulators or law enforcement where applicable; and
  • maintain records, audits and internal controls, and to manage and improve the Portal (including troubleshooting and analytics, where enabled).

Where required, we will obtain your consent for certain collections or uses (for example, where you expressly authorize us to obtain additional medical records).

4. Disclosure of Personal Information

4.1 Limiting Disclosures

We do not disclose personal information for purposes other than those described above unless you consent, or applicable law permits or requires it. We may disclose personal information to the following categories of recipients, as needed for the claims process:

  • ACL, and other parties to the proceedings where relevant to claim administration (including General Dynamics and/or certain insurers, as applicable to the claim you assert);
  • our professional advisors and service providers (including legal counsel, auditors, claims administration support, and IT/hosting providers) who assist us in operating the Portal and administering claims;
  • Grant Thornton Advisors LLC for U.S. claim intake support and related administration (where applicable);
  • courts, regulators, and law enforcement authorities where required or permitted by law (e.g., pursuant to a court order or other valid legal process); and
  • other entities involved in fraud prevention, security incident response, or risk management, where necessary to protect the claims process and our systems.

4.2 Cross-border Flows of Data

Personal information may be processed, accessed, or stored in Canada, the United States, and potentially other jurisdictions where our service providers operate. These jurisdictions may have different data protection laws than your place of residence. In such cases, personal information may be subject to access by courts, law enforcement, and national security authorities in accordance with the laws of the relevant jurisdiction. Any cross-border flows of personal information will be carried out according to applicable laws.

5. Retention of Personal Information

We retain personal information for no longer than reasonably necessary to administer the claims process and to comply with applicable legal, court, and professional obligations. Retention periods may extend beyond the end of the insolvency proceedings where required for recordkeeping, auditing, or to address disputes, litigation, or regulatory inquiries.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal information has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

6. Consent

Where required by applicable law, we will obtain your consent for the collection, use, or disclosure of personal information. In some cases, withdrawing consent may limit our ability to process your claim or provide Portal functionality.

You may withdraw consent where applicable by contacting us using the details in the Contact section, subject to legal and contractual restrictions.

7. Security Measures

We follow the standards that are generally applied and recognized for this purpose, in order to ensure the protection of personal information. We maintain physical, organizational, contractual and technological security measures to protect your information against accidental or unlawful destruction, accidental loss, modification, unauthorized disclosure or access, misuse or other unlawful form of processing of personal information in our possession. We take steps to ensure that only authorized individuals who have a need-to-know personal information, or whose duties reasonably require knowing it, have access to it. Third parties to whom personal information is communicated must comply with the security measures we have implemented.

Despite the measures described above, no method of transmission over the Internet, nor any means of electronic storage, is completely secure. We therefore cannot guarantee the absolute security of your personal information. If you have reason to believe that your personal information has been compromised, please contact us using the contact details provided in the "Contact us" section below.

8. Links to Third Party Websites

For your convenience, the Portal may provide links to third party sites or portions of their sites. We have no control over the content or operation of these sites or the confidentiality or privacy practices of the operators of these sites. We are not responsible for the privacy practices of third-party sites. We encourage you to review their privacy notices.

9. Rights Concerning Your Personal Information

Depending on your jurisdiction and subject to applicable legal limitations (including court and recordkeeping requirements), you may have rights to request access to, correction of, or deletion of your personal information, and to lodge a complaint with a relevant privacy regulator.

U.S. state privacy disclosures (where applicable): We do not sell your personal information or share it for cross-context behavioral advertising. If you are a resident of a U.S. state that provides privacy rights (e.g., California), you may have additional rights, including the right to know the categories of personal information collected and disclosed, and the right to request access, correction, or deletion, subject to exemptions.

10. Contact

If you have questions, concerns, or requests regarding this Notice or our handling of personal information in connection with the claims process, you may contact us at:

Email: asbestoscorp@rcgt.com
Mail (Canada): Raymond Chabot Inc., Attention: Asbestos Corporation Limited, 600 De La Gauchetiere Street West, Suite 2000, Montreal, Quebec H3B 4L8
Mail (U.S.): Grant Thornton Advisors LLC, Attention: Asbestos Corporation Limited, 757 Third Ave., 9th Floor, New York, NY 10017

11. Updates to this Notice

We may update this Notice from time to time. We will post the updated version on the Portal and update the "Last updated" date above.

ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individual residents of certain states in the United States. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Notice.

Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by contacting us at asbestoscorp@rcgt.com.

Applicable United States Privacy Disclosures

These Additional United States Privacy Disclosures (for residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia) apply solely to and provide additional information about how we collect, use, disclose and otherwise process personal data, either online or offline, of individual residents of certain states in the United States as required under applicable law.

Personal Data Disclosures, Sales, and Targeted Advertising

We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Disclosure of Personal Information section of our Privacy Notice. However, we do not sell personal data, and we do not process or otherwise share personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual's activities across non-affiliated businesses or websites, applications, or other services (otherwise known as "targeted advertising" or "cross-context behavioral advertising").

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

Please note we do not sell the personal data of individuals we know to be less than 18 years of age or share such information for targeted advertising purposes.

Sensitive Personal Data

The following personal data elements we collect may be classified as "sensitive" under certain privacy laws:

  • Government ID numbers, including social security number, driver's license number, state identification card number, or passport number; and
  • Health data, including information regarding an individual's medical history, mental or physical health condition, or medical treatment or diagnosis.

We do not use or disclose "sensitive personal information" (as defined in the California Consumer Privacy Act ("CCPA")) for purposes other than those permitted under the CCPA and its implementing regulations.

De-identified Information

We may at times receive, or process personal data to create, de-identified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified information, we will maintain and use the information in de-identified form and not attempt to reidentify the information except as required or permitted by law.

Your Additional U.S. Privacy Choices

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  • Right to Know: The right to confirm whether we are processing personal data about you and, for residents of California and Oregon only, to obtain certain personalized details about the personal data we have collected about you, including:
    • the categories of personal data collected;
    • the categories of sources of the personal data;
    • the purposes for which the personal data were collected;
    • the categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed;
    • the categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and
    • the categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold.
  • Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
  • Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties, including the right to opt-out of the disclosure of personal data to third parties for the third parties' direct marketing purposes under California's "Shine the Light" Law.
  • Right to Deletion: The right to have us delete personal data we maintain about you.

For Residents of Delaware, Minnesota, and Oregon

Right to a List of Third Parties: The right to request a list of the specific third parties (as defined under applicable law) to whom we disclose personal data. To exercise this right, please email us at asbestoscorp@rcgt.com.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by:

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form and toll-free number to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent's authority to act on your behalf. In order to verify the authorized agent's authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.

Additional California-Specific Disclosures

The following disclosures only apply to residents of the State of California.

California Categories of Personal Data

California law requires we provide disclosures to you about what personal data we collect by reference to the enumerated categories of personal data set forth within California law. To address this obligation, we have identified the relevant enumerated California personal data category for the personal data described in the Our Collection and Use of Personal Data section of our Privacy Notice below:

  • Identifiers, such as full name and contact information;
  • Customer records, such as work history and claim information;
  • Protected classification characteristics, such as disability status, age/date of birth or other characteristics that may appear in medical records;
  • Commercial information, such as claimed medical expenses, lost wages, pension or Social Security benefit information;
  • Biometric information;
  • Internet / network information, such as device information, logs and analytics data;
  • Geolocation data, such as IP-based approximate location;
  • Professional or employment-related information, such as claimed medical expenses, lost wages, pension or Social Security benefit information;
  • Other Personal Data, such as attorney details and RCI communications; and
  • Inferences, conclusions drawn from claim information, medical records, and exposure history.

California's "Shine the Light" Law

California's "Shine the Light" law (Civil Code Section 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. It is company policy that we do not disclose personal information to third parties for their direct marketing purposes if a consumer has exercised their right to opt out. To opt out of having your personal information disclosed to third parties for their direct marketing purposes, please follow the instructions for opting out of targeted advertising above.

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