Privacy Policy
North America

The purpose of this Policy is to describe what personal information is collected from our customers, job applicants, employees, former employees, shareholders, service providers, professional advisors, suppliers, contractors, subcontractors and individuals who visit the Website and how we collect, use, share, protect and store their personal information.

When used in this Policy, “personal information” shall have the meaning set forth in the legislation that is applicable to you. For instance, for residents of Canada, personal information means any information which can be used to, directly or indirectly, identify a person.

We may collect, use, store and transfer different kinds of personal information about you which we have categorized as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Protecting the privacy of persons under the age of 14 is especially important. For that reason, we never collect or maintain information from persons we actually know are under 14, and no part of our services are structured to attract anyone under 14. If a person under 14 has provided personal information to us, we ask that a parent or guardian of the person please contact our Privacy Officer if they would like us to stop processing such information and have it removed from our database and we will use all reasonable efforts to do so.

• Information We Collect Directly from You. We collect information about you that you provide us with voluntarily. When you subscribe to our newsletter, we collect your name and email address. When you contract with us to receive our services, we may in addition collect your phone number, your company name, mailing address and email address. We may also collect your credit card details to process payment. When you apply for a position at Solotech or when we hire you, we, or our processing partners, will collect your contact details, including your date of birth, your address and previous addresses, employment and education history.

• 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. We may also collect information from credit reporting agencies to assess your eligibility for the products and services requested.

• Information We Collect Automatically. We automatically collect Technical Data about you when you use our Websites. We collect this personal information by using cookies and other similar technologies. When you receive an email from us, we may also collect whether you opened such email. We may combine this information with other information that we have collected about you, including, where applicable, your name and other personal information.

• 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.

At or before the time of collection, we inform individuals of the purposes for which their personal information is being collected, the means of collection, and the rights available to them under applicable privacy laws. Where required by applicable law, we identify any personal information that is considered sensitive and obtain express consent for its collection, use, or disclosure.

We collect, use, and disclose your personal information primarily with your consent, except where otherwise permitted or required by applicable law. Your consent may be express or implied, depending on the sensitivity of the information and the reasonable expectations of privacy in the circumstances.

In certain cases, we may process personal information without consent where permitted by law, including to comply with legal obligations, to prevent fraud, or as otherwise authorized under applicable privacy legislation.

We have set out below, in a table format, examples of how we plan to use your personal information. Note that we may process your personal information for more than one purpose depending on the circumstances.

Use of Personal Information for Marketing

We may use your Identity, Contact, Technical, Usage and Profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing!).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. We strive to provide you with choices regarding personal information uses, particularly around marketing and advertising. If you no longer wish to receive commercial electronic messages from us, please let us know by following the unsubscribe directions provided in every commercial electronic message any of us send, or you can send an email to marketing@solotech.com.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will notify you to obtain your consent, unless applicable laws require or allow us to use your personal information for that unrelated purpose without further notice.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Website. You can set your browser to refuse all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

We may share your personal information within our group companies in accordance with this Policy. We also may subcontract the processing of your personal information to or otherwise share your personal information with service providers located in Canada, United States, United Kingdom and Europe. Whenever we transfer your personal information outside of the country where it was collected, we ensure that appropriate safeguards are implemented according to applicable data protection laws.

Where personal information is stored or used outside of the jurisdiction where it was initially collected, the personal information will be subject to the law of the jurisdiction in which it is used, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

Where required by applicable law, we conduct a privacy (or transfer) impact assessment to evaluate the risks associated with such transfers and implement appropriate safeguards to ensure that your personal information receives a level of protection comparable to that required under the laws of your jurisdiction.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the country where it was collected.

Our websites may contain links to third-party websites, such as online job boards. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

We store your personal information for only as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Please note that if your personal information is collected by a third party, it will be retained in accordance with the privacy policies and records retention requirements of that third party.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed as set out below. These measures include physical, administrative and electronic security measures that are reasonable given the sensitivity of the personal information collected, the amount, distribution and format of the personal information, and the methods of storage and include but are not limited to the following:

Firewalls. We ensure that connections between our internal systems and the internet are protected by firewalls.

Encryption. We ensure that any personal information in transit is encrypted to industry standard.

Monitoring. We monitor our systems for vulnerabilities and signs of attack and carry out penetration tests annually to assess the strength of our defences.

Identity Verification. Before divulging your personal information in response to a telephone call or email enquiry, we ask you for proof of identity in order to ensure that we do not provide your personal information to someone else.

General Security Safeguards. We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. We also use physical access controls.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In addition, your personal information is password protected and we limit access to your personal information and any sensitive material and data to those employees, agents, contractors and other third parties who have a business need to know so they can only access the personal information they need in order to perform their job. They are also subject to confidentiality obligations.

We also require all employees to undertake data protection training so that they are aware of their data protection obligations to ensure that personal information is handled appropriately and securely (including any sensitive material and data).

Under certain circumstances and depending on where you live, you may have rights under data protection laws in relation to your personal information. These rights can include the following:

Request access to your personal information. This enables you to receive a copy of the personal information we hold about you (subject to certain restrictions).

Request correction of your personal information. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it or where we are required to erase your personal information to comply with local law. However, please note that this is not an absolute right as we may have legal or legitimate grounds for retaining your personal information.

Request the transfer of your personal information. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.

To exercise any of these rights please contact our Privacy Officer using the details set out in the “Contact Us” Section. Please note that we may not always be able to fully address your request, such as if doing so would impact the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.

If you are a U.S. resident, please see our Privacy Notice for U.S. Residents [link] to learn about the privacy rights available to you, how you may exercise those privacy rights, and how we respond to privacy rights requests.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure that you are entitled to exercise any of the rights provided above. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to exercise these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time Limit to Respond

We try to respond to all legitimate requests within 30 days. Occasionally, it could take us longer to respond where applicable laws allow this, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

You have the right to make a complaint at any time to your country-specific regulator for data protection issues (“Regulator”). We would, however, appreciate the chance to deal with your concerns before you approach the Regulator, so please Contact Us in the first instance.

This Policy is current as of the Effective Date set forth above. We reserve the right to modify this Policy to adapt it to any technological or legal change, to adjust it to reflect changes made to the Website or for any other purpose. All updates to our Policy will be posted on this page or otherwise mentioned to you if required by applicable laws.

We have appointed a global privacy officer (“Privacy Officer”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our Privacy Officer using the details set out below:

By email: privacyofficer@solotech.com; or

By mail: 5200 Hochelaga Street, Montréal (Québec) H1V 1G3

To the attention of: Legal Department – Solotech Privacy Officer

If you want to opt-out from our commercial electronic messages, please send an email to that effect to marketing@solotech.com.