Legal · Privacy Policy
What personal information Zentek Ltd. collects through this website, why we collect it, and the choices you have.
Last updated 24 September 2026
Zentek Ltd. (the “Corporation”) is committed to controlling the collection, use and disclosure of personal information. The Corporation has demonstrated its commitment by developing this privacy policy (the “Privacy Policy”) in accordance with the standards set out in the Personal Information Protection and Electronic Documents Act (Canada) (the “Act”). As part of its privacy policy initiative, the Corporation has also developed a privacy statement, which may be published on its website. A copy of the proposed privacy statement is attached to this Privacy Policy as Schedule “A”.
It is the Corporation’s intention to use this Privacy Policy as a set of recommended best practices to mold the development and ongoing implementation of its privacy procedures, as an evolving resource for its employees and as a guide for the public of its initiatives to protect the privacy of personal information. The principles set out in this Privacy Policy seek to balance the right of privacy of an individual with respect to their personal information and the Corporation’s need to collect, use or disclose personal information for legitimate business purposes, on a standard of what a reasonable person would consider appropriate in the Corporation’s particular circumstances.
As a general proposition, any personal information that the Corporation collects will not be disclosed to third parties. The intent is that the information will be used solely for the exclusive use of the Corporation. However, in order to improve the integrity of the information collected, to assist in maintaining security over the information collected or as may be required by law, personal information may need to be disclosed.
The Corporation recognizes that controlling and safeguarding the collection, use and disclosure of personal information is an ongoing process. The Corporation is committed to reviewing this Privacy Policy on an ongoing basis and to updating the principles listed herein to better protect the privacy of individuals. As part of this commitment the Corporation invites all interested parties to review the following ten privacy principles listed below and submit any comments they may have to the Corporation’s Privacy Officer (as defined below).
The Corporation is responsible for all personal information in its possession or control. In fulfilling this mandate the Corporation has appointed a privacy officer (the “Privacy Officer”, currently the Corporation’s Chief Executive Officer, who can be reached by regular mail at 1123 York Road, Guelph, ON N1E 6Z1, Canada). Accountability for compliance by the Corporation with the principles and policies listed in this Privacy Policy rest with the Privacy Officer even though other individuals within the Corporation may be responsible for the day to day collection and processing of personal information. The Privacy Officer may, from time to time, designate one or more individuals within the Corporation to act on his or her behalf to ensure the compliance by the Corporation with the principles and policies listed herein. The designation of a Privacy Officer does not relieve the Corporation from responsibility for compliance with these principles. The Corporation monitors compliance with the policies and principles on an ongoing basis.
The Corporation has implemented policies and practices that give effect to the principles and procedures of this Privacy Policy including:
The Corporation collects personal information for the following purposes: establishing and maintaining communication with individuals; offering and providing information to meet individual investors’ needs; compiling statistics; and complying with the law. Without limiting the generality of the foregoing the information collected may also be used in particular to: create usage and website activity summary statistics; direct development and customization of general and online investor services and communications; and assist and develop marketing material and information circulars.
The purposes for which personal information is collected shall be identified before or at the time that the information is collected. The purpose of the information collected, used or disclosed by the Corporation must be apparent and is held accountable to a standard of what a reasonable person would consider appropriate in the circumstances. The Corporation will make reasonable efforts to identify the purposes for which personal information is collected to an individual from whom the personal information is collected at or before the time of collection. Depending upon the way in which the information is collected, the Corporation will identify these purposes on its website, as well as verbally or in writing, upon request.
The Corporation recognizes that collection of personal information is an evolving process and for personal information that has been collected for a purpose not previously identified, it will identify and obtain consent to the new purpose prior to use, except as permitted or required by law.
To the extent necessary, employees of the Corporation collecting personal information from an individual will explain to such individual the purpose for which the information is being collected, including any other purpose that may not be immediately obvious to the individual.
The knowledge and consent of an individual is required for the collection, use or disclosure of personal information, except where consent is not required under the Act. In order to fully comply, the Corporation will make a reasonable effort to ensure that the individual is advised of the purposes for which his or her personal information will be used or disclosed in a manner that is reasonably understood by the individual.
The form of consent sought may vary depending upon the circumstances and the type of information collected. In determining the form of consent to seek, the Corporation will take into account the sensitivity of the information. Although some information (for example medical records and income records of employees) is almost always considered sensitive, any information can be sensitive depending on the circumstances. In seeking consent the Corporation will take into account the reasonable expectations of the individual in the particular circumstances.
Generally, the Corporation will seek consent for the collection, use or disclosure of personal information at the time of the collection. In certain circumstances consent with respect to use or disclosure, as applicable, may be sought after the information is collected but before use (for example, when the Corporation wants to use the information for a purpose not previously identified).
The Corporation collects only the personal information necessary for the purposes identified. Information shall be collected by fair and lawful means. The Corporation will not collect personal information indiscriminately.
When possible the Corporation will collect personal information from the individual directly. However, depending on the particular circumstances the Corporation may obtain personal information from other third party sources.
Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
If using personal information for a new purpose, the Corporation will document this purpose.
Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous. The Corporation will develop guidelines and implement procedures to govern the destruction of personal information.
Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. The extent to which personal information will be accurate, complete, and up to date will depend upon the use of the information, taking into account the interests of the individual.
The Corporation will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
Personal information that is used on an ongoing basis, including information that may possibly be disclosed to third parties, will generally be accurate and up to date, unless limits to the requirement for accuracy are clearly set out.
The Corporation will ensure that security safeguards appropriate to the sensitivity of the information will be implemented to protect personal information. The security safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The Corporation will protect personal information regardless of the format in which it is held.
The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. A higher level of protection will safeguard more sensitive information, such as medical and health records of employees, as appropriate.
The methods of protection will include:
The Corporation will make its employees aware of the importance of maintaining the confidentiality of personal information and care will be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
The Corporation will make readily available to individuals specific information about its policies and practices relating to the management of personal information. The Corporation will be open about its policies and practices with respect to the management of personal information and an individual will be able to acquire information about the Corporation’s policies and practices without unreasonable effort. This information will be made available in a form that is generally understandable.
The information made available will include:
In addition, the Corporation may make information on its policies and practices available in a variety of ways. For example, the Corporation may choose to make brochures available in its place of business, mail information to its clients, post signs in its offices, or provide online access.
Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
In certain situations, the Corporation may not be able to provide access to all the personal information it holds about an individual. Exceptions to the access requirement will be limited and specific. The reasons for denying access will be provided to the individual upon request.
Upon request, the Corporation will inform an individual whether or not it holds personal information about the individual. The Corporation will seek to indicate the source of this information and will allow the individual reasonable access to this information. In addition, upon request, the Corporation will provide an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed, as appropriate.
An individual will be required to provide sufficient information to permit the Corporation to provide an account of the existence, use, and disclosure of personal information. The information provided will only be used for this purpose.
The Corporation will respond to an individual's request within a reasonable time and at minimal or no cost to the individual. The requested information will be provided or made available in a form that is generally understandable.
If an individual demonstrates the inaccuracy or incompleteness of certain personal information, the Corporation will amend the information as required. Depending upon the nature of the information challenged, amendment may involve the correction, deletion, or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the personal information in question.
When a challenge is not resolved to the satisfaction of the individual, the Corporation will record the substance of the unresolved challenge.
An individual will be able to address a challenge concerning compliance with this Privacy Policy with the Privacy Officer.
The Corporation will put procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures will be easily accessible and simple to use. The Corporation will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. A range of these procedures may exist and are evolving. The Corporation will investigate all complaints. If a complaint is found to be justified, the Corporation will take appropriate measures, including, if necessary, amending its policies and practices.
This policy was adopted and approved by the Board effective January 1, 2020.
Your privacy is very important to us. This brief statement summarizes certain aspects of our privacy policy (the “Privacy Policy”). To view the Corporation’s complete Privacy Policy, please visit the Corporation’s Website at zentek.com/privacy.html.
The information that we collect may be used for the following purposes, among others:
The Corporation collects and uses your personal information in order to provide you with the services that you request and to facilitate the flow of investor information. We also may use your personal information to provide you with further information about our Corporation, unless you advise us that you do not want such information. To tell us that you do not wish such information or if you require further information to make this decision or if you wish to withdraw consent to our collection of your personal information, please click here.
This website may use "cookies", small text files inserted on your computer to identify your computer as you view our website, in order to provide you with an enhanced experience. However such cookies are never linked to your personal information.
By providing the Corporation with your personal information, including your e-mail address, you are deemed to have consented to the Corporation using it for the purposes described above.
The Corporation collects the following information regarding visitors to our website: domain name, name, information regarding which pages are accessed, information volunteered by you, such as survey information, e-mail addresses or website registrations and your preferred means of communication. The Corporation collects and logs this information for statistical purposes.
As a general proposition, the Corporation will not disclose your personal information to third parties. The intent is that the personal information collected will be used solely for the exclusive use of the Corporation. However, in order to improve the integrity of the data, to assist in maintaining security over the data, or as required by law, some personal information may be required to be disclosed.
The Corporation takes reasonable security measures to protect personal information from loss, unauthorized access, destruction, misuse, modification and disclosure. The Corporation treats the information with a high degree of regard and awareness of the private confidential nature of the data. Our primary objective is to maintain the integrity and security of the data.
Controlling and safeguarding the collection, use and disclosure of personal information is an ongoing process and we anticipate that at some time in the future it may be necessary to make changes to our Privacy Policy. If in our opinion, acting reasonably, such changes will allow the Corporation to make materially greater use or disclosure of your personal information, we will notify all active users of the changes. Such investors will then have an opportunity to withdraw their consent to the collection, use or disclosure of their personal information. The content of the Privacy Policy may be updated from time to time and we suggest that you return to the website on a regular basis and carefully read the information provided.
If you wish to access any of your personal information held by the Corporation, have further questions about your personal information and/or the Corporation’s Privacy Policy or procedures, wish to withdraw all or part of your personal information, or have any other concerns, please contact:
Attention: Privacy Officer
Zentek Ltd.
1123 York Road
Guelph, ON N1E 6Z1
Canada
Email: privacy@zentek.com
The sections below add detail about personal information collected through this website (the “Site”) to the Privacy Policy and Privacy Statement above. In them, “Zentek”, “we”, “us” and “our” mean Zentek Ltd. (the “Corporation”). They do not apply to third-party websites we link to, each of which has its own privacy practices.
If you submit the investor relations or business development enquiry forms on our Contact page, we receive the information you enter. Depending on the form, this may include your name, organization, email address, the nature and subject of your enquiry, and the message you write. Fields marked as required are needed for us to respond; anything else is optional. If you email us directly, we receive your email address and whatever you choose to include.
Please do not include sensitive personal information in an enquiry, and do not send us confidential or non-public information through the Site.
Our hosting provider records standard technical information when a page or file is requested, which typically includes your IP address, the date and time of the request, the page or document requested, the referring page, and your browser and operating system type. These server logs are used to operate, secure and troubleshoot the Site.
If — and only if — you accept analytics cookies, Google Analytics also records information about how you use the Site, as described in Cookies and similar technologies.
We do not knowingly collect payment card details, government identifiers, health information or other sensitive categories of personal information through the Site, and the Site does not host advertising or third-party ad tracking.
Where the General Data Protection Regulation or the UK GDPR applies to you, our lawful bases are: consent, where you voluntarily submit an enquiry and where you accept analytics cookies as described in Cookies and similar technologies; legitimate interests, in operating and securing the Site, responding to correspondence and maintaining business records, where those interests are not overridden by your rights; and legal obligation, where we must retain or disclose information to comply with law.
The Site uses Google Analytics 4 to understand how the Site is used. Analytics is off unless you turn it on. No request is made to Google Analytics and no analytics cookie is set until you choose “Accept” on the cookie banner shown on your first visit. If you decline, or simply ignore the banner, Google Analytics is never loaded and collects nothing. The server logs and web-font request described elsewhere in this policy happen either way.
If you accept, Google Analytics records information about your use of the Site. This includes the pages you view and when, how you reached the Site, approximate location derived from your IP address, and technical details of your device and browser such as device type, operating system, browser, screen size and language. It may also record interactions such as scrolling, outbound link clicks, file downloads, site searches and video engagement. It does not record your name or contact details, and we do not attempt to identify you from it.
Google Analytics sets cookies named _ga and _ga_<identifier> in your browser, configured to expire two years after they are last set, although most current browsers cap the lifetime of cookies set this way at a shorter period — Chromium-based browsers such as Chrome and Edge currently limit them to 400 days. They distinguish one browser from another so that repeat visits are not counted as separate visitors. The information is collected and processed by Google as our analytics provider and is subject to Google’s privacy practices; it may be transferred to and stored on servers outside Canada, including in the United States. We have configured the tag so that Google Advertising Features and advertising personalisation are disabled: analytics information is not used for advertising and is not shared with Google’s advertising products. We do not combine it with information you submit through an enquiry form, and the Site sets no advertising, social-media or cross-site tracking cookies and uses no tracking pixels or web beacons.
You may change your choice at any time using the Cookie settings button in the footer of any page. Declining stops any further analytics collection and removes the analytics cookies held in the browser you are using at the time; it cannot remove information already transmitted to Google, and it applies only to that browser. Your choice is recorded in your browser’s local storage for twelve months, after which you will be asked again; because it is stored per browser, you will also be asked again on another browser or device, or if you clear your site data.
Your browser may cache Site files; this is a function of your browser rather than a tracking technology deployed by us. The Site loads web fonts from Google Fonts, which means your browser makes a request to Google’s servers that includes your IP address and is subject to Google’s privacy practices. That request is made whether or not you accept analytics cookies.
Zentek is based in Canada, and our service providers may store or process information in Canada, the United States or other countries. Personal information held in another jurisdiction may be accessible to the courts, law enforcement and national security authorities of that jurisdiction under its laws.
Where we transfer personal information out of the EEA, the United Kingdom or Switzerland, we rely on an applicable transfer mechanism, such as standard contractual clauses or an adequacy decision. You may contact us for further information about the safeguards we use.
Enquiry correspondence is generally retained for as long as needed to handle the enquiry and any resulting relationship, and thereafter for a reasonable period as a business record. Server logs are retained for a short period in the ordinary course of our hosting provider's operations. Where a legal hold, investigation or claim applies, we retain the relevant information until it is resolved.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send sensitive or confidential information to us by unencrypted email or through the Site.
Where the GDPR or UK GDPR applies, you may additionally have rights to restrict or object to processing, to receive your information in a portable format, and not to be subject to decisions based solely on automated processing. We do not use your Site information to make decisions about you by automated means, and we do not build marketing or advertising profiles. Where you have accepted analytics cookies, the analytics measurement described in Cookies and similar technologies groups visits by browser in order to report on Site usage.
To exercise a right, contact us using the details in Contacting us and complaints.
The Site is intended for adults - primarily investors, analysts, commercial counterparties, prospective employees and professional advisers. It is not directed at children, and we do not knowingly collect personal information from anyone under the age of majority in their jurisdiction of residence. If you believe a child has provided us with personal information, please contact us and we will delete it.
To ask a question about this policy, to exercise a privacy right, or to make a complaint about how we have handled your personal information, contact:
Privacy Officer, Zentek Ltd.
1123 York Road
Guelph, ON N1E 6Z1
Canada
Email: privacy@zentek.com
We will acknowledge your complaint, investigate it and inform you of the outcome. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca, or, if you are in the EEA or the United Kingdom, your local supervisory authority.