Solotech California Consumer Privacy Act Notice

Effective Date: October 13, 2022

Last Updated on: October 13, 2022 

This Privacy Notice for California Residents (“Notice”) supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Notice.

 

A. Information We Collect

We 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 or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of Personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other Personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

 

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.

 

B. Use of Personal Information

We may use or disclose the Personal information we collect for one or more of the following 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 the CCPA.
  • 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.

 

C. Sharing Personal Information

We may share your Personal information by disclosing it to a third party for a business purpose. 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 information for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

We may disclose your Personal information for a business purpose to the following third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your Personal information in connection with products or services we provide to you.
  • Operating systems and platforms.
  • Data analytic providers.
  • Internet cookie data recipients, like Google Analytics.

We do not sell Personal information. In the preceding twelve (12) months, we have not sold any Personal information.

 

D. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:

  • 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).

Right to Delete

You have the right to request that we delete any of 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:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described 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

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal information. You may also make a request to know or delete on behalf of your minor child. You may only submit a request to know twice within a 12-month period.

Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal information or an authorized representative of that person.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal information if we cannot verify your identity or authority to make the request and confirm the Personal information relates to you. You do not need to create an account with us to submit a request to know or delete.  We will only use Personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

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 should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

E. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • 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.

 

F. Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on our Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

G. Contact Information

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 California law, 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 due to having a disability, please contact privacyofficer@solotech.com.