We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer, household, or device (“Personal Information“).

Personal Information does not include: Publicly available information from government records. Deidentified data, Aggregate Consumer Information, and information excluded from the scope of Applicable State Privacy Laws, such as information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act and the Health Insurance Portability and Accountability Act.

We have collected the following categories of Personal Information from Consumers during the last twelve (12) months:

We do not collect categories of Sensitive Personal Information from Consumers.

Because of the many purposes and use cases for Personal Information, we are unable to provide retention periods based on categories of Personal Information in a way that would be meaningful and transparent to you. Actual retention periods for Personal Information depend on how long we have a legitimate purpose for the retention — consistent with the collection purposes and applicable law.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Information We Collect Directly from You. We collect information about you that you provide us with voluntarily. For example, when you subscribe to our newsletter, when you contract with us to receive our services and when you apply for a position with us.
• Information We Collect from Third Parties. We collect information about you from third parties, including content you post or interactions you have on social media networks where we maintain corporate pages, such as Facebook and LinkedIn.
• Information We Collect Automatically. We collect information about you when you use our websites. For example, your browser type and operating system, pages you view, links you click, your IP address, language preference and address of referring website.
• Information We Collect from Technologies at Our Locations. We may collect Personal Information through various types of technologies used at our offices. These can include video surveillance within our office and in areas surrounding our offices.
• Information We Collect from our Vendors. We may collect Personal Information from our Processors, Service Providers and Contractor (each as defined in Applicable State Privacy Laws) (collectively, “Vendors”).

We may collect, retain, use, or disclose the Personal Information we collect to provide you our products and services, or information about them, and as otherwise related to the operation of our business, including for one or more of the following Business Purposes:

• To fulfill or meet the reason you provided the information.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in Applicable State Privacy Laws.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

In the preceding twelve (12) months, we have disclosed Personal Information as set forth in Section A. above.

We only make these Business Purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed Personal Information for any purpose except performing the contract.

We do not “Sell” or “Share” Personal Information or use it for Targeted Advertising as these terms are defined under Applicable State Privacy Laws. In the preceding twelve (12) months, we have not Sold or Share any Personal Information.

Applicable State Privacy Laws provide Consumers with specific privacy rights regarding their Personal Information. This section describes these privacy rights and explains how to exercise them.

For individuals who are not granted privacy rights under Applicable State Privacy Laws, we will consider privacy rights requests on a case-by-case basis but will apply our discretion with respect to if and how we process the requests.

Subject to certain exceptions and limitations, which we will explain to you in response to your request if we are relying on an exception, you may have the following rights:

1. Right to Know – Categories and Specific Pieces

You have the right to request that we disclose the following information to you about our collection and use of your Personal Information during the past 12 months:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our Business or Commercial Purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• If we disclosed your Personal Information for a Business Purpose, a list identifying the Personal Information categories that each category of recipient obtained.
• The specific pieces of Personal Information we collected about you (also called a data portability request) and to receive a copy of the Personal Information in a structured, commonly used, machine-readable and transportable format to the extent technically feasible.

(If you are a California resident, you also may have the Right to Know for Personal Information collected on or after January 1, 2022.)

2. Right to Delete

You have the right to request that we delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete from our records or deidentify Personal Information not subject to one of the exceptions below and will direct our service providers to take similar action.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Right to Correct

You have the right to request that we correct inaccuracies that you find in the Personal Information about you maintained by us.

4. Right to Opt-Out of Sale/Share

We do not Sell or Share Personal Information or use Personal Information for Targeted Advertising. In the preceding twelve (12) months, we have not Sold or Share any Personal Information.

Certain web browsers also may provide a do-not-track (DNT) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.” Because there is not yet a common understanding of how to interpret web browser-based DNT signals other than cookies, our websites do not currently respond to DNT signals.

5. Right to Limit Sensitive Personal Information Processing

We do not process Sensitive Personal Information of Consumers.

6. Automated Decision Making/Profiling Rights

We do not engage in automated decision making or profiling that is currently subject to Consumer rights under Applicable State Privacy Laws.

To exercise the privacy rights described in Section E. above, please submit a request by either:

• Email: privacyofficer@solotech.com
• Postal Address: 5200 Hochelaga Street, Montréal (Québec) H1V 1G3
  Attn: Legal Department – Privacy Officer

1. 1. Verifiable Consumer Request Requirement

Only you or someone legally authorized to act on your behalf (i.e., your authorized agent) may make a request related to your Personal Information.

As permitted or required by Applicable State Privacy Laws, when you make a request, we may ask you to provide verifying information, such as your name, email, phone number, so that we can reasonably verify you are the California Applicant about whom we collected Personal Information. Once we verify your request, we refer to it as a “Verifiable Consumer Request.”

As permitted by Applicable State Privacy Laws, we may verify the following types of requests:

• Right to Know (Categories): We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you. If we cannot do so, we will refer you to this Notice for a general description of our data practices.
• Right to Know (Specific Pieces): We verify your request to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, which we have determined to be reliable for the purpose of verifying you together with a signed declaration under penalty of perjury that you are the Consumer whose Personal Information is the subject of the request. If you fail to provide requested information, we will be unable to verify you sufficiently to honor your request, but we will then treat it as a Right to Know (Categories) request.
• Right to Delete: We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion.
• Right to Correct: We verify your request to a reasonable degree of certainty, which may include matching at least two data points provided by you with data points maintained by us, or to a reasonably high degree of certainty, which may include matching at least three data points provided by you with data points maintained by us, depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized correction.

If we are unable to sufficiently verify you, we are unable to honor your privacy right request. We will use Personal Information provided in a Verifiable Consumer Request only to verify your identity and authority to make the privacy right request and to track and document the response to a privacy right request unless you also gave it to us for another purpose.

2. Authorized Agent Requirements

You may use an agent to make a request to delete, request to correct, or a request to know. Before an agent can act on your behalf, we require a completed Authorized Agent Authorization Form or a power of attorney pursuant to Probate Code sections 4121 to 4130 (POA).

We may require that you verify your identity or directly confirm that you authorized the agent to submit the request unless you provide a POA. Once verified by us or if your agent has a POA, your agent becomes an “Authorized Agent” and may exercise the rights to delete, correct, and know on your behalf, subject to the requirements of Applicable State Privacy Laws.

3. Responses and Timing of Responses

We will make commercially reasonable efforts to identify the Personal Information that we process to respond to a privacy rights request. In some cases, particularly with voluminous requests, we may suggest that you receive a summary of your Personal Information and offer you the opportunity to elect whether you want to receive all of it. We reserve the right to direct you to where you may access and copy responsive Personal Information yourself. We typically do not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee or refuse to act upon a request if your request is excessive, repetitive, unfounded, or overly burdensome, as permitted under Applicable State Privacy Laws. If we determine that the request warrants a fee or that we may refuse it, we will notify you, explaining why we made that decision. We will provide a fee estimate and the opportunity to accept the fee before we charge you for responding to your request.

We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt.

If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, based on the method you have elected to send us your request.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and intended to allow you to transmit the information from one entity to another entity without hindrance.

4. Appeals

You may appeal our decision regarding a privacy rights request you submitted (or that was submitted on your behalf by your authorized agent) by following the instructions provided in our response to your request.

We will not discriminate against you for exercising any of your State Privacy Law rights. Unless permitted by Applicable State Privacy Laws, we will not do the following if you exercise your privacy rights:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We do not currently offer discounts or rewards to Consumers for providing us Personal Information or set price or service differences related to the collection or retention of Personal Information. If we do so in the future, we will update this Notice and explain how you may opt-in and how we value the Personal Information required.

Notwithstanding anything to the contrary, we may collect, use, and disclose your Personal Information as required or permitted by applicable law and this may override your rights under Applicable State Privacy Laws. In addition, we are not required to honor your requests to the extent that doing so would infringe upon our or another person’s or party’s rights or conflict with applicable law.

We reserve the right to amend this Notice to address changes in our practices.  We will notify you of material changes to this Notice by posting the updated version on this webpage and, for material changes that reduce your privacy rights, by notifying you by email at the email address on file with us or another method that we determine is appropriate.

If you have any questions or comments about this Notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under Applicable State Privacy Laws, please do not hesitate to contact us at:

Email: privacyofficer@solotech.com

Postal Address: 5200 Hochelaga Street, Montréal (Québec) H1V 1G3
Attn: Legal Department – Privacy Officer

If you need to access this Notice in an alternative format, please contact privacyofficer@solotech.com.