Privacy Policy

Effective date: June 2019

1. Scope and application

Groupe Solotech Inc. and its affiliates (“Solotech,” “we,” “us,” or “our”) value your privacy.

A. What Is the Purpose of This Privacy Policy?

The purpose of this Privacy Policy (“Policy”) is to describe what personal information is collected from our customers, job applicants, website users and individuals who visit our premises, and how we collect, use, share, protect and store their personal information.

When used in this Policy, “personal information” means any information which, directly or indirectly, make a person identifiable, such as that person’s name or email address.

B. How Can This Privacy Policy Apply to You?

This Policy can apply to you in a number of ways, which include when you visit one of our websites, apply for a position, sign-up to receive our newsletter or to be a part of any of promotions, contests or events, or receive our services. Please note that specific privacy notices and/or additional terms and conditions may apply to how we are collecting and managing your information when you engage with some of our programs, products, services, promotions, contests and/or events. Those specific privacy notices and/or terms and conditions will apply together with this Policy.

Protecting the privacy of persons under the age of 13 is especially important. For that reason, we never collect or maintain information from persons we actually know are under 13, and no part of our services are structured to attract anyone under 13. If a person under 13 has provided personal information to us, we ask that a parent or guardian of the person contact 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. For contact information, see Whom Do I Contact with Privacy Questions?

C. To Whom Does This Privacy Policy NOT Apply?

This Policy does not apply to the information practices of third-party companies that we refer to in this Policy or elsewhere on our website (including their websites, platforms and/or applications), which we do not own or control. These third parties may have their own privacy policies and terms and conditions. We encourage you to read them before providing your information to them.

2. Type of Personal Information We Collect About You

We collect information about you directly from you and/or from third parties, as well as automatically through your use of our websites [and/or mobile apps].

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 and mailing address. We may also collect your credit card details to process payment. When you apply for a position at Solotech, we, or our processing partners, may collect your contact details, including your date of birth 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.

Information We Collect Automatically. We automatically collect the following information about you when you use our websites [and/or mobile apps]: your browser type and operating system; pages you view; links you click; your IP address; language preference; and address of referring website. 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.

3. Using Your Personal Information

We generally use your personal information to provide our services, for our own internal purposes, as described hereinafter, as well as for marketing and advertising purposes, although in this last case, subject to your right to withdraw consent provided by this Policy and further explained in the section Your Legal Rights below. We may also anonymize and/or aggregate personal information so that it no longer identifies you, and use it for any legal purpose.

We use your personal information for the following purposes:

A. Providing Products and Services

We use your personal information in order to provide you with our products and services, which includes:

• Providing you with a quote for a product or service;
• Verifying your identity;
• Determining your eligibility for a product or service;
• Creating, administering, and maintaining your customer account;
• Processing your transactions; and
• Fulfilling your product and service requests, inquiries, and purchases.

B. Managing our Business

We use your personal information in order to manage our businesses, which includes:

• Processing your job applications;
• Maintaining quality service levels;
• Deploying and managing our information technology applications and systems, including managing our websites [and/or mobile apps];
• Managing and facilitating the use of our websites [and/or mobile apps], which may include using cookies and other similar technology;
• Enabling your participation in contests, promotions and surveys;
• Maintaining the security of the public and our customers, employees and property (e.g., through video surveillance);
• Protecting parties from errors and fraud;
• Monitoring and investigating incidents and managing claims;
• Maintaining our products and services; and
• Meeting our legal or regulatory obligations.

C. Communicating with You

We use your personal information in order to communicate with you in a variety of ways, which includes:

• Providing you with information and updates about our products, services, promotions, contests and events;
• Responding to your inquiries;
• Taking or verifying instructions from you;
• If we have your consent, informing you in a variety of ways (e.g., email, telephone, SMS, direct mail) about services, special offers, promotions, contests or events that may be of interest to you;
• Delivering interest-based advertisements relating to our services or third-party products and services that may be of interest to you; and
• Sending electronic invoices/confirmations of services.

Unless you tell us otherwise or consent is required by law, we may contact you by any means for which you have provided contact information.

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. For more information, please see Your Legal Rights section.

D. Conducting Data Analytics

We, or our processing partners, may use your personal information in order to conduct data analytics for purposes, such as:

• Managing and developing our business and operations;
• Improving our products and services (e.g. improving the navigation on our websites);
• Understanding customer needs and preferences [and customizing how we tailor and market products and services to our customers based on their interests]; and
• Measuring the effectiveness of our marketing.

When doing so, we generally will use your information in an aggregated format or with direct personal identifiers removed.

4. Disclosing Your Personal Information

We may share your personal information within our group of companies or with our service providers for the purposes described in this Policy and in accordance with applicable law. We do not sell your personal information to any other organization or person, except in the event of a sale or transfer of all or part of our business.

More specifically, we may disclose personal information as follows:

• Affiliates. We may disclose the information we collect about you to our affiliates for the purposes described in this Policy; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
• Service Providers. We may disclose the information we collect about you to third party vendors, service providers, contractors, processors or agents who help us operate our business, such as online job boards, website hosting companies and email service providers.
• Business Transfers. We may decide to sell or transfer all or part of our business to a related company or to a third party, to merge with another entity, to insure or securitize our assets, or to engage in another form of corporate or financing transaction (including the proceedings of insolvency or bankruptcy, corporate reorganization, sale of shares, or other change in corporate control). If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information during and after completion of the transaction. Any third party that we transfer or sell our assets or shares to will have the right to continue to use your personal information, provided that they comply with applicable privacy legislation and with this Policy.
• In Response to Legal Processes. We may also disclose the information we collect from you in order to comply with the law, a judicial proceeding, a court order, or another legal process, such as in response to a subpoena.
• To Protect Us and Others. We may also disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreement with you or this Policy, or as evidence in litigation involving Solotech.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about you with third parties for marketing, advertising, research or similar purposes.
• With Your Consent. Besides for the purposes listed above, we may, with your express consent as applicable, share or disclose your personal information outside of our group of companies, in accordance with applicable law.

5. Legal Basis

In general, by subscribing to our services and/or submitting information to us in connection with using our products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information. If you are located in the EU, we rely on Lawful Basis for EU Data Subjects to process your personal information, which are detailed below.

A. How Do We Manage Consent?

Unless we determine that we require an additional consent for specific products, services, contests, promotions or events, you agree and consent that we may collect, use, share or otherwise process your personal information in accordance with this Policy.

We will obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection, in this Policy or in the terms and conditions of a specific product, service, contest, promotion or event you signed up for, participated in or purchased.
Your consent can be withdrawn at any time, except for limited circumstances, including legal or regulatory requirements that we have or contractual obligations you have with us. For information on how to manage your privacy preferences, please see Your Legal Rights below.

If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the products, services, contests, promotions, events or information that you requested or that could be offered to you.

B. Lawful Basis for EU Data Subjects

If you are located in the European Union, we process your personal information on the following legal basis:

• You consented to our processing of your personal information (for example, when you opt-in to receiving our newsletter). You may withdraw your consent to the use of your personal information for promotional purposes at any time, in accordance with your right to withdraw consent, further explained in the section Your Legal Rights, below;
• Our processing of your personal information is in our legitimate interest or in the legitimate interest of a business partner (for example in order to make improvements to our services); you have a right to object to such processing as explained in the section below entitled Your Legal Rights;
• Our processing of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example where you purchase our services); and/or
• Our processing of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).

6. Cross-border Transfer of Information

Solotech, or our processing partners, may maintain servers and systems in Canada and the United States, Europe and Asia. We also may subcontract the processing of your personal information to, or otherwise share your personal information with, affiliates and third parties located in the United States. Where personal information is stored or used outside of Canada, it is 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 the personal information that we collect through or in connection with our services is transferred to and processed in the United States for the purposes described in this Policy, we will take steps to ensure that the information receives an adequate level of protection, including by entering into data transfer agreements.

7. Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our website. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

When you use our websites [and/or mobile apps], we may use the following tracking mechanisms:

• Cookies are small text files that are saved on your device’s hard drive through your web browser for record-keeping purposes.
• Web beacons are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail.
• Single pixel gifs are small image files similar to web beacons that allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized aggregate form (i.e. in a manner where we cannot identify you). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
• Other technologies, such as Data Management Platform (DMP) services and analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization, targeted advertising, customizing content and other methods to gain insights into our customers’ needs and preferences.

We may combine information collected through these mechanisms with other information that is collected offline or online such as your transaction history (e.g. if you are subscribe to our newsletter online and order our services over the phone, we may combine this information into your customer profile) in order to evaluate use our websites [and/or mobile apps] and to support website analytics as well as advertising and marketing campaigns, subject to your right to withdraw consent.

We may also use Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses cookies to analyze your use of our websites, to create reports about visitor activities for us and to provide further services associated with the use of the websites and the Internet. Although this information is collected through your Google ad settings, it is not provided to us in a personally-identifiable format.

The type of cookies and tracking mechanism we use are described in our cookie consent which also describes how you may delete or disable certain of these technologies. However, if you do so, you may not be able to use some of the features on our website.

8. Third-Party Links

Our websites [and/or mobile apps] 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.

9. Retention of Your Personal Information

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).

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.

10. Security of Your Personal Information

We have implemented technical and organizational measures to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. These measures include physical, administrative and electronic (technological) 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. However, there is always a certain level of risk involved when personal information is collected, processed and stored and we are unable to guarantee the security of your personal information.

11. Your Legal Rights

You have the right to access the personal information we hold about you, subject to any legal restrictions. We will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your personal information or need to update it, please let us know through the steps outlined below.

You also have the right to withdraw your consent at any time, subject to certain requirements.

Further, if you are located in the European Union, the Lawful Basis for EU Data Subjects section below describes the additional legal rights available to you under European Union law.

A. Right to access and correct your information

You can request access, update or correct the personal information we hold about you by contacting our Privacy Officer, through email or postal mail (for contact information, see Whom Do I Contact with Privacy Questions?). Please note it is your responsibility to provide accurate, correct and complete information.

If the Privacy Officer is unable to address your concern to your satisfaction, you may bring the matter to the attention of the appropriate Privacy Commissioner. Some of our activities are subject to the jurisdiction of the Office of the Privacy Commissioner of Canada; other activities are subject to the jurisdiction of the Privacy Commissioner of your province or country of residence.

B. Right to Withdraw Consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to the processing of personal information for purposes that are necessary to provide our services, we may limit the services we are able to provide to you. You may withdraw your consent for purposes not necessary to provide our Services, as detailed in this section of the Policy.

Please note that even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws. For example, for customer service, product information, service or reminder notices, or recalls. We may also need to contact you with questions or information regarding your order, such as regarding order status, shipment, or refunds. It may take some time for all of our records to reflect changes in your preferences. For example, if you request that you not receive email marketing communications from us, your preference may not be captured for a promotion already in progress.

Should you have any questions or how to opt-out of our communications and advertisements, please contact marketing@solotech.com

C. Additional EU Data Subject Rights

Subject to certain conditions, and in some cases dependent upon the processing activity we are undertaking, EU data subjects have additional rights in relation to their personal information.

Right to access, correct, and delete your personal information. You have the right to request access to the personal information that we hold about you as well as the following information: (i) the source of your personal information; (ii) the purposes, legal basis and methods of processing; (iii) the data controller’s identity; and (iv) the entities or categories of entities to whom your personal information may be transferred. You also have the right to request that we delete your personal information. We are not required to comply with your request to delete personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.

Right to restrict the processing of your personal information. You have the right to restrict the processing of your personal information in the following circumstances: (i) you contest the accuracy of the personal information; (ii) the processing is unlawful but you wish to restrict rather than prohibit the processing of your personal information; (iii) the purposes for processing your personal information no longer exist, but you require the personal information for the establishment, exercise, or defence of legal claims; or (iv) you have legitimately objected to the processing of your personal information and the processing is therefore restricted pending the verification of whether the legitimate grounds of the controller override your objection.

We can continue to process your personal information following a request for restriction:

• if we have your consent;
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

Right to data portability. To the extent that we process your personal information (i) based on your consent or under a contract and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to a data controller.

Right to object to the processing of your personal information. You can object to any processing of your personal information based on our legitimate interests (or on the legitimate interests of one of our partners) if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.

Right to lodge a complaint with your local supervisory authority. You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

D. Additional Information

Before handling your request to exercise your legal rights, we may ask you for additional information to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

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.
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12. Whom Do I Contact with Privacy Questions?

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

If you have any questions about how we handle your personal information, please contact our Privacy Officer by email or by postal mail at:

Solotech Privacy Officer
5200 Rue Hochelaga, Montréal (Québec) H1V 1G3
privacyofficer@solotech.com

Should you have any questions or concerns pertaining to a third party’s privacy practices, we will direct you to the appropriate contact so that you may make enquiries as to that party’s privacy policies and practices.

13. Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our website [and/or mobile apps] and make same available to you in hard copy format upon request. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our websites [and/or mobile apps