I. Corporate Commitment to Privacy

Solace and its subsidiaries and affiliates are committed to respecting your privacy. This Privacy Policy describes how we collect, use, disclose, store and otherwise process information through solace.com and its affiliated websites and other online Solace products and services. In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy.

We urge you to read this Privacy Policy so that you understand our commitment to you and your privacy, and how you can participate in that commitment.

II. GDPR Compliance

Solace complies with the General Data Protection Regulation (GDPR) as set forth by the European Parliament in April 2016. GDPR mandates that Solace protects the personal data and privacy of EU data subjects. If there is any conflict between this privacy policy and GDPR, the GDPR principles shall govern.

III. Definition of Personal Information

Personal information refers to any information relating to an identified or identifiable natural person, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers (“personal information”).

IV. Definition of Non-Personal Information

We may also collect information that is related to you but that does not personally identify you (“non-personal information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.

V. Scope

This privacy policy applies to personal information and non-personal information collected by Solace or its service providers from or about:

(i) visitors to, or users of, its websites;

(ii) prospective and current customers using Solace hosting and information technology services;

(iii) users of any mobile-device applications that it offers (such as its iOS and Android applications);

(iv) service providers and business partners;

(v) job applicants; and

(vi) other third-parties that it interacts with.

VI. Consent

Solace collects personal information about you in connection with many of our services. You may be prompted to make an account which may hold personal information such as your name, mailing address, email address, or credit card information. Prior to collecting this information, Solace will obtain your consent. At any point in time, you can revoke consent and we will cease using and processing your data immediately.

VII. Information Collected Automatically

Solace may also collect Technical Information about you when you visit our websites, which your web browser automatically sends whenever you visit a website on the Internet. “technical information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol (“IP“) address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support our customer analytic efforts.

Email communication – We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.

Mobile communication – When you download or use our mobile-device applications, or access one of our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device.

Cookies and Similar Technologies – We may collect information about your use of the websites through cookies and similar technology. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.

reCAPTCHA – We have implemented the Google reCAPTCHA API to enhance the security of certain of our websites and to prevent bots from creating accounts. Solace’s use of reCAPTCHA is limited strictly to fighting spam and abuse of Solace website properties and is used for no other purpose.

VIII.  Information Collected from Social Media Applications/Networking Websites

Our websites include social media features. These features may collect your IP address and which page you are visiting on our site and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the organization providing it.

IX. Information Collected from Other Sources

Solace may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services) and may receive information about you from them. The following are some examples:

Third-Party Vendors – In order to provide the services and improve Solace’s websites, we may engage the services of third-party vendors. In the process of supplying services to Solace, these third-party vendors may need to collect Personal Information about you.

Co-branding – Some company websites or services may be co-branded and offered in conjunction with another company. If you use such websites or services, both Solace and the other company may receive the Personal Information that’s collected via that co-branded website or service.

Public Forums, Blogs and the Customer Reference Program – Solace websites may feature bulletin boards, blogs or forums. Any Personal Information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages.

Flash LSOs – We use Local Storage Objects (LSOs) such as HTML5 and Flash to store content information and preferences. We partner with third parties to provide certain features on our site or to display advertising based upon your browsing activity. Various browsers may offer their own management tools for removing HTML5 LSOs.

Log Files – Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help Solace determine (among other things) how many and how often users have accessed or used our services, which pages they’ve visited, and other similar data.

Clear GIFs – Clear GIFs, sometimes called “web bugs” or “web beacons,” are small electronic images that are placed on a web page or in an email message. We use clear GIFs to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness, and to tell if a recipient has opened and acted upon an email.

X. Permitted Use of Personal Information

Solace uses your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine personal and non-personal information, collected online and offline, including information from third party sources.

Fulfill Requests – To fulfill your requests for products and services and communicate with you about those requests;

Understand Customer Behavior – To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services;

Personalize Offerings – To help us personalize our service offerings, websites, mobile services, and advertising;

Credit Card Information – Credit card information may be used to check the financial qualifications or collect payment from customers regarding orders of products and services;

Protection – To protect the security and integrity of our websites, mobile services, and our business;

Legal – To comply with legal and/or regulatory requirements;

Responding to Customer – To respond to reviews, comments, or other feedback you provide us;

Industry Benchmarking – For industry benchmarking and analysis consistent with our legitimate business purpose;

Employment Applications – In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background or resume and other information. We may use this information throughout Solace, its subsidiaries and affiliates, and its joint ventures for the purpose of employment consideration.

XI. Promotional Messaging or Advertising

Solace uses your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers or to notify you about our upcoming events.

XII. Ability to Opt-In to Promotional Messaging or Advertising

Solace allows you to opt-in to receive advertisements based on your interests. If you do not opt-in, you will still receive advertisements but they will not be tailored to your interests. Solace also allows you to opt-in to receive communications, such as mailings or text message marketing. To opt-out of advertisements, visit https://go.solace.com/UnsubscribePage.html.

XIII. Disclosure of Personal Information to Third Parties

Solace will not rent or sell your Personal Information to others but may disclose personal information with third-party vendors and service providers that work with Solace. We will only share personal information to these vendors and service providers to help us provide a product or service to you. Examples of third parties we work with are call center operators, shippers, servicers, information processors, and financial institutions. These third parties only have access to personal information necessary for them to complete their service.

XIV. Disclosure of Personal Information for Legal and Safety Reasons

Solace may be required to disclose personal information to government authorities, law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to:

a) comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law;

b) in the event of an emergency that threatens an individual’s life, health, or security; or

c) to the extent permitted by applicable law in special cases in which we believe it is reasonably necessary to investigate, identify, or take preventive measures or bring legal action against someone who may commit or cause harm, fraud, abuse, or illegal conduct, such as a threat of harm to you or anyone else, interference with our rights or property, or interference with U.S. homeland or national security or public safety anywhere in the world.

XV. Disclosure of Personal Information Via Links to Third-Party Websites, Services, and Applications

Using our website or services may link you to third party websites, services, and applications. Solace is not responsible for any personal information collected through these means. Information collected is governed through the third party’s website’s Privacy Policy. Any interactions you have with these web websites, services, or applications are beyond the control of Solace. When you post information to or through such services, those websites’ privacy policies and cookie usage policies apply directly. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

XVI. Use of Cookies and Other Technologies (e.g. Web Beacons)

Solace uses cookies to operate and improve our website as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience and advertisements. Cookies help us better understand user behavior and facilitate effectiveness of advertisements. Cookies only stand to recognize your web browser but information collected from cookies is not personally identifiable. Solace may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily used to provide content and advertisements that are more relevant to you.

XVII. Ability to Disable Technologies

Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services. For more information, visit the help page for your web browser or see http://www.allaboutcookies.org

XVIII. Consequences of Disabling Technologies

Please note that if you disable your web browser’s cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.

XIX. Security Measures Taken to Protect Personal Information by Company

Data Breach Notification

Security of all information is of the utmost importance for Solace. Solace uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. We use encryption technology to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to personal information. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you. We will notify relevant regulatory bodies within 72 hours of a breach.

XX. Security Measures to Protect Personal Information by Third Parties

We require that our third party service providers and channel partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third party service providers and channel partners are expected to maintain privacy and security protections that are consistent with Solace’s privacy and information security policies.

XXI. Data Retention and Storage

Solace retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. Solace will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. At any point in time, you can withdraw consent and we will immediately stop processing your data.

XXII. Choice: Your Privacy Rights

Solace gives you choices about the ways we collect, use, and share your personal information. You can choose what contact and financial information will be stored and preferences. If at any point in time you wish know what data we process about you, you can request to access the information by contacting our Data Protection Officer at dpo@solace.com.

XXIII. Access to and Correction of Personal Information

Solace allows you to access and update your personal information. You can ensure that any account, contact, or financial information is up-to-date and can correct, update or delete inaccuracies to the information by contacting the Company. We will respond to your request to access within three days. Solace will attempt to answer all requests that we correct the data if it is inaccurate or delete it as long as Solace is not required to retain it by law or for legitimate business purposes. In some jurisdictions, in addition to you agreeing to this Privacy Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations). In addition, to protect your privacy, we will require you to prove your identity before granting access to, or agreeing to update, correct or delete your Personal Information and we will only implement requests with respect to Personal Information about you (not anyone else).

XXIV. Collection of Information from Children

The Company recognizes the importance of protecting the privacy and safety of children. Our website and services are primarily directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13. A parent or guardian of a child may contact us at dpo@solace.com to request that we delete such information.

XXV. International Transfer of Personal Information

Solace may share customer information within our family of companies for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions. To facilitate our global operations, Solace may transfer personal data from your home country to other Solace locations across the world. To protect your personal information, we will only transfer data to countries who provide an “adequate” level of personal data protection. If the data is transferred to countries without ‘adequate’ protection as determined by the European Parliament, we will use additional safeguards to ensure your data is protected.

XXVI. Questions/Updates to Policy

Customers may contact Solace with any questions, concern, or inquiries about this Privacy Policy or company data. If you would like to make a formal complaint, please contact Solace at: Data Protection Officer, Solace Corporation, 4000 Innovation Drive, 3rd Floor, Ottawa, Ontario, K2K 3K1, Canada, or dpo@solace.com. All complaints will be evaluated and a reply will be sent as soon as appropriate. In some instances, the Solace may have to cease services to you if necessary to satisfy your request.

In compliance with GDPR, Solace commits to resolve complaints about your privacy and our collection/use of your personal information. If you have an inquiry or compliant regarding this privacy policy should first contact Solace at: Data Protection Officer, Solace Corporation, 4000 Innovation Drive, 3rd Floor, Ottawa, Ontario, K2K 3K1, Canada or dpo@solace.com.

Solace may review and update this Privacy Policy periodically without any prior notice. Solace will post a notice to its website to inform you of any changes to our Privacy Policy and indicate when it was most recently updated. In the case of material changes that may adversely affect you, Solace may provide a more direct way of notifying you of changes to this Privacy Policy.

XXVII.  Contact Point to Update/Delete Personal Information

You have the right to access and limit the use and disclosure of your personal data. If you would like to express your point of view, challenge an explanation of data use, or otherwise obtain further information, contact dpo@solace.com.  If at any time after registering for information, your personal information changes, notify us and we will update your contact information. Please note, at any time, if you desire to obtain or transfer your information, we will provide you with your personal data in a structured and commonly used electronic format.

XXVIII. Location of Data Processing/Storage

Any personal information collected about EU data subjects via our websites is processed in Canada and the United States by Solace or by a third party acting on our behalf. When you provide personal information to Solace, you consent to the processing of your information in Canada and the United States. Our websites are hosted in Canada.

XXIX. Applicable Regulations – California Privacy Rights

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to dpo@solace.com or write us at Data Protection Officer, Solace Corporation, 4000 Innovation Drive, 3rd Floor, Ottawa, Ontario, K2K 3K1, Canada.

XXX. GDPR Rights

Right of Access – At any point in time, you may confirm your data is being processed and request to access your data. If you wish to access/confirm your data is being processed, please contact dpo@solace.com.

Right to Consent – Before collecting and using your personal data, Solace will obtain consent. At any point in time, you can revoke consent and Solace will stop using and processing your personal data.

Right to Erasure – You have the right to request Solace to erase all of your personal data on a number of grounds, including if the data is no longer necessary for its original purpose or if you withdraw consent. If Solace receives a request, we will inform all third parties who have the data of this request. For additional information on when you can request data erasure, please contact dpo@solace.com.

Right to Rectification – If any personal data is inaccurate or incomplete, you can request Solace corrects the data. When this occurs, Solace will notify third parties who have access to the data of the change. If you wish to alter your data, please contact dpo@solace.com.

Right to Restrict Processing – Even if personal data is still stored by Solace, now or in the future, you can request Solace stops using or processing your data. If you wish to restrict data processing, please contact dpo@solace.com.

Right to Object – You have the right to object to your personal data being processed for profiling, direct marketing, scientific research, and statistics. If you wish to object, please contact dpo@solace.com.

Rights Related to Automatic Decision Making and Profiling – At any point in time, you can contact a Solace representative to express your point of view, challenge an explanation of data use, or otherwise obtain further information on automatic data processing.

Right to Data Portability – You have the right to transfer your personal data from one electronic processing system to another without being prevented from doing so by Solace’s data processor.