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Effective date: October 23, 2023

Groupe Solotech Inc. and its affiliates (“Solotech”, “we“, “us” or “our“) value your privacy and are committed to protecting your personal information. This privacy policy (“Policy”) will inform you as to how we collect, use and otherwise process your personal information.

This Policy applies to all personal information collected by Solotech through technological means or other means, including through all Solotech websites, such as the website http//www.Solotech.com/ and all authorized sub-sites that expressly adopt, display or link back to this Policy (collectively, the “Website”). In the event that a privacy policy specific to a particular Website or service has been published, that specific privacy policy will apply.

When using the Website, you also have responsibilities which are outlined in the Terms and Conditions section of the Website https://www.solotech.com/terms-and-conditions/. We recommend that you consult these Terms and Conditions prior to using the Website in order to inform yourself of your obligations.

This Policy covers all personal information that we collect, use and otherwise process when you interact with the Website or with us. All personal information will be processed in accordance with this Policy and with applicable laws, which can vary depending on your country of residence. If you do not agree with any provisions or changes to this Policy, please do not use the Website.

This Policy is provided in a layered format so you can click through to the specific areas set out below.

1. Purpose and Application

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 legal residents of the European Union, “personal information” shall be read throughout this Policy as “personal data” as defined under the General Data Protection Regulation (“GDPR”): meaning any information which, directly or indirectly, make a person identifiable, such as that person’s name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. It does not include data where the identity has been removed (i.e., anonymous data).



2. Collection of Personal Information

What Types of Information Do We Collect About You?


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.


We do not collect any Special Categories of Personal information about you without your prior express consent. This includes details about your ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health (except in relation to certain employee benefits such as insurance), and genetic and biometric data.


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 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.


How is Your Personal Information Collected?


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.

3. Using your Personal Information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Purposes for Which We Use Your Personal Information

We have set out below, in a table format, examples of how we plan to use your personal information and which of the legal basis (according to the GDPR) we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your data.

Table Example

Purpose/Activity Type of Data Lawful Basis for Processing
(in accordance with the GDPR)
To provide you with our products and services, which includes:
• Verifying your identity
• Determining your eligibility for a product or service
• Creating, administering, and maintaining your customer account
• Processing your transactions and delivering purchased products
• Fulfilling your product and service requests, inquiries, and purchases
Marketing and Communications
✓ Performance of a contract with you
✓ Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
• Notifying you about changes to our terms or policies
• Asking you to leave a review or take a survey
• To answer to your requests or questions
• Processing your job application
• Maintaining our products and services
Marketing and Communications
✓ Performance of a contract with you
✓ Necessary to comply with a legal obligation
✓ Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, to develop them and grow our business)
For employment purposes such as:
• Payroll, pension, insurance and other benefits
• Employee administration and management
• Recruitment, performance management and career development
• Health and safety
✓ Performance of a contract with you
✓ Necessary to comply with a legal obligation
✓ Necessary for our legitimate interests (to attract and retain employees, to keep our records updated, to grow our business)
To administer and protect our business and this Website Identity
✓ Necessary to comply with a legal obligation
✓ Necessary for our legitimate interests (provision of administration and IT services, network security, to prevent fraud)
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity
Marketing and Communications
✓ Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences Technical
✓ Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Identity
Marketing and Communications
✓ Necessary for our legitimate interests (to develop our products/services and grow our business)

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 and we will explain the legal basis which allows us to do so.
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.

4. Use of Cookies and other Tracking Technologies

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 https://www.solotech.com/cookie-policy/.

5. 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. 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 data protection laws and with this Policy.
In Response to Legal Processes. We may also disclose the information we collect from you in order to comply with applicable laws, 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.


We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. Cross-border transfer of Information

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. For example, for residents of the European Union and United Kingdom:


• We will transfer your personal information to countries that have been deemed by the European Commission to provide an adequate level of protection for personal information (“Adequate Country”) (for more information, click here); or
• Where we use certain service providers that are not located in an Adequate Country, we will take steps to ensure that the information receives an adequate level of protection, including by entering into data transfer agreements or by inserting specific data protection clauses in our contracts.


Where personal information is stored or used outside of the country 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.


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.

8. 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).

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.

9. Security of your Personal Information

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. 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.

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, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

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.

Object to processing of your personal information. This will apply where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

     o If you want us to establish the data’s accuracy.

     o Where our use of the data is unlawful but you do not want us to erase it.

     o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

     o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.



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 one (1) month. Occasionally, it could take us longer than a month 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.



Appeal Process


Depending on where you live, you may have the right to appeal our refusal to take action on a request to exercise any of your legal rights. This appeal must be submitted to our Privacy Officer within thirty (30) days of receiving our refusal to take action and must contain the reasons why you think we should fulfill your request Contact Us.


We try to respond to all legitimate appeal request within forty-five (45) days. We may extend the forty-five-day (45) period by an additional sixty (60) days period where reasonably necessary, taking into account the complexity and number of requests serving as the basis for the appeal. In this case, we will notify you and keep you updated.





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.

11. California Privacy Rights

If you are a resident of California, you may have additional rights regarding your personal information. For information on how to exercise your rights under the California Consumer Privacy Act (“CCPA”), visit our California Privacy Rights privacy notice here https://www.solotech.com/privacy-notice-for-california-residents/.

12. Changes to this policy

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.

13. Contact us

We have appointed a global privacy officer (“Privacy Officer”) who is responsible for overseeing questions in relation to this Policy as well as country-specific privacy officers. 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.