I. Corporate Commitment to Privacy
II. GDPR Compliance
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.
(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.
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
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
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 firstname.lastname@example.org.
XXIII. Access to and Correction of Personal Information
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 email@example.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
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 firstname.lastname@example.org. 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 email@example.com or write us at Data Protection Officer, Solace Corporation, 535 Legget Drive, 3rd Floor, Ottawa, Ontario, Canada K2K 3B8.
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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org.
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.