Solimar Systems, Inc. Privacy Statement

This privacy statement covers the websites and applications of Solimar Systems, Inc. (“Solimar” or “we”) that include a link to this statement. This privacy statement also applies to Solimar’s marketing and advertising practices where and when it is referenced. It is meant to inform you about our collection and use of your personal data.

You may choose to give us personal data to allow us to communicate with you, process your orders, provide you with services, or for employment consideration. Data we collect depends on the context of your interactions with Solimar, the choices you make, including your privacy settings, and the products and features you choose. The personal data we collect can include the following:

Name and Contact Data. Your name (including first, middle and last names), email address, postal address, phone number and other similar contact data in order to communicate with you, process orders or provide you with products or services. We may also collect your employer name, if you are procuring products or services on behalf of an organization.

Credentials. Passwords, password hints and similar security information used for authentication and account access.

Demographic Data. Data about you such as your country of residence and preferred language.

Payment Data. Data necessary to process your payment if you make purchases, such as your payment card number, expiration date, and the security code associated with your payment card.

Geolocation Data. We may collect data about your location, which can be either precise or imprecise. Precise location data can be obtained through Global Navigation Satellite System data, as well as through nearby cell towers and Wi-Fi hotspots when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your device or data that indicates where you are located with less precision, such as an internet protocol (IP) address or a city or postal code.

Social Media Data. We may provide social media features that enable you to share information with your social networks. Your use of these features may result in the collection or sharing of information about you by the social networking site. Please review the privacy policies and settings of social networks you use to understand their practices.

Job Applications/CVs/Resumes. Professional, education and employment-related information on job applications/CVs/resumes which you provide to us if you submit a job application to Solimar either directly or indirectly, which may include sensitive personal data. Solimar uses this information in order to evaluate your application and perform related employment activities.

Feedback and Product Reviews. Information you provide to us and the content of messages you send to us, such as feedback and product reviews you write, blog posts or questions and information you provide for customer support. When you contact us via our website, a Solimar application or by phone, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded. Your feedback, posts and reviews will be used to seek improvements in our products and services.

Website Browsing and Commercial Information. Information about your visits to our websites and your browsing patterns, including inferences drawn from this information. This may include information related to your prior purchases and online buying preferences or data about your device, including IP address, browser type, and regional and language settings. This is more fully described under the section entitled “Cookies, Web Beacons and Privacy Choices” below. We collect this information to determine such things as the number of visitors to various parts of our websites, to personalize your experience on our sites, and tailor our interactions with you.

One of the third parties we use to collect and track user statistics and trends related to our sites and services is LeadLander, Corp. through its LeadLander product offering (“LeadLander”). LeadLander’s privacy policy and how the LeadLander services operate and use data from our sites and services is available at: https://leadlander.com/privacy-policy/. As part of our use of our website we will install cookies onto your computer on behalf of LeadLander. You acknowledge and consent to the placement of such cookies which will collect data about your use of our site and services and other sites and services which utilize LeadLander’s services. In addition, if you provide us with personal information (including name, e-mail address, company affiliation and similar personally identifying data) we may provide this information to LeadLander so they can associate it with the cookie we have installed on your computer which will allow them to identify you on other sites which utilize the LeadLander service and share your information with the third parties who operate those sites.

Products. Certain Solimar products collect data, such as product registration, device serial number, equipment configuration and settings, software version, and fault codes. Solimar uses this information for product improvement, billing, report generation, and support services.

Third-party Sources. We also obtain data from third-parties. These third-party sources vary over time, but they are sources deemed credible by us and may be publicly available or available on a commercial basis. They can include:

• Data brokers from which we purchase demographic data to supplement the data we collect;
• Social networks when you grant permission to a Solimar product to access your data on one or more networks;
• Designated entities within your business or enterprise (such as a member of your IT department) in the course of providing services to you;
• Partners with whom we offer branded services or engage in joint marketing activities. If you purchase Solimar services or products from a Solimar partner we may receive certain information about your purchase from that partner;
• Fraud prevention agencies or credit reporting agencies in connection with credit determinations; and
• Publicly available sources such as open government databases or other data in the public domain.

You may elect to disclose or send content to us to analyze or test and that contains personal information of third parties, typically consumers. Such content that includes personal information of third parties is subject to disclosure restrictions in privacy laws or private agreements. By disclosing or sending to us such content that includes personal information of third parties, you certify that you are lawfully allowed to do so for the limited purpose of such analysis or testing.

We collect and process personal data with your consent, as required by law, or as necessary to fulfill the legitimate interests or business purposes of Solimar, including to: (i) provide you with products and services; (ii) manage, administer and operate our business; (iii) meet our contractual and legal obligations; (iv) carry out direct marketing; (v) prevent fraud; and (vi) protect the security of our systems and our customers.

Solimar uses personal data to:

• respond to your questions and communicate with you;
• provide customer support;
• share news, updates, or helpful tips about Solimar products and services;
• inform you of special promotions and other advertising;
• allow you to sign up for online services;
• create reseller partnerships;
• receive and evaluate job applications;
• customize, analyze, and improve our products, services, technologies, communications and relationships with you;
• deliver products and services requested by you; and
• notify you about administrative matters that pertain to your Solimar products or services.

Personal data that is submitted in a business capacity may be merged with available business database directories.

We share your personal data as necessary for Solimar’s business purposes, to complete a transaction or provide a product or service you have requested or authorized. For example, when you provide payment data to make a purchase, we will share your payment data with banks and other entities that process payment transactions or provide other financial services, and with consumer reporting agencies for fraud prevention and credit risk reduction.

We share personal data among Solimar subsidiaries to efficiently manage the operation of our business. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement or in our contracts with you. In addition, we may share information with third parties for the joint offering of a product or service. In such cases, these companies are required by contract to abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will transfer or disclose personal data when we have a good faith belief that doing so is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
• Protect our customers, for example to prevent attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone; or
• Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.

We do not sell your personal data to third parties.

Personal data collected by Solimar may be transferred to, stored and processed in your region, the United States, or any other country in which Solimar or its subsidiaries, sub-contractors, agents or partners maintain facilities. Our subsidiaries, sub-contractors, agents and partners are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by Solimar. We also take steps to provide adequate protection for any transfers of your personal data in accordance with applicable law.

Our privacy guidelines are communicated to Solimar employees on a periodic basis. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located. Sometimes we transfer personal data from the European Economic Area and Switzerland to other countries. When we do, we use a variety of legal mechanisms to help ensure any required rights and protections apply to your data.

Solimar Systems, Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework established by the U.S. Department of Commerce regarding the collection, use and retention of personal data transferred from the European Union and Switzerland to the United States. Solimar Systems, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If third-party agents process personal data on our behalf in a manner inconsistent with the Privacy Shield Principles, we remain liable unless we prove we are not responsible for the event giving rise to the damage. If there is any conflict between the terms in this privacy statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Solimar commits to resolve complaints about our collection or use of your personal data. European Union or Swiss individuals with inquiries or complaints regarding this privacy statement should first contact Solimar at privacy@solimarsystems.com and indicate “Privacy Shield” in the Subject line.

Solimar further commits to cooperate with the panel established by the EU data protection authorities or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel or commissioner with regard to data transferred from the EU or Switzerland. You may also be able, under certain conditions, to invoke binding arbitration.

The Federal Trade Commission has jurisdiction over Solimar’s compliance with the Privacy Shield.

Solimar retains personal data for as long as necessary to provide the products and fulfill the services and transactions you have requested or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Actual retention periods can vary. The criteria used to determine the retention periods include: (i) how long personal data is needed to provide our products or operate our business; (ii) whether the personal data is of a sensitive type; and (iii) whether Solimar is subject to a legal, contractual or similar obligation to retain the data.

You have choices about the data we collect. When you are asked to provide personal data, you may decline; however, if you choose not to provide data that is necessary to provide a product or feature, you may not be able to use that product or feature.

• If the processing of personal data is based on your consent, you have a right to withdraw consent at any time for future processing;
• Where applicable, you have a right to request from us, (i) access to and receipt of personal data, (ii) transfer of personal data, and (iii) rectification or deletion of your personal data;
• You may also have a right to object to or restrict the processing of your personal data;
• You have the right to object to direct marketing (you may unsubscribe via an ‘opt-out’ provided in the communication); and
• You have a right to file a complaint with a regulator or data protection authority.

You may contact Solimar to check the accuracy of your personal data or to request that your information be updated or deleted by writing to privacy@solimarsystems.com. Please indicate “Access” in the subject line and let us know the details of your request in the body of the message. Solimar reserves the right to confirm your identity and to modify the scope and number of requests. In certain cases, your request may be denied on the basis of a legitimate exception or where we are legally prevented from honoring such request.

Solimar does not direct any part of its website to children under 13 years old (or such age as a child is defined by local law if higher) and does not knowingly collect personal data from children or target its website or products to children. If we learn we have collected or received personal data from a child under 13 years old without verification of parental consent, we will delete the information.

Solimar is committed to protecting the security of your personal data and maintains strict access control over it. We utilize reasonable and appropriate physical, technical and administrative procedures to safeguard personal information we collect and process. Only authorized Solimar personnel, and those of our subsidiaries, agents, and partners are allowed to handle information collected by Solimar.

Solimar websites store personal data in password-protected environments on servers that are subject to Solimar’s information security policies, standards, and procedures. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit sensitive personal data such as a password over the Internet, we protect it through the use of encryption.

When you provide personal data to Solimar, it may be necessary to transfer personal data to our subsidiaries, agents or partners, who then fulfill the orders or provide the services. Solimar requires that its subsidiaries, agents and partners handle personal data with the same concern for personal data privacy as Solimar.

What is a Cookie?

Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work efficiently, as well as to provide information to the owners of the site. Cookies are useful because they allow a website to recognize your device, letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.

How Does Solimar Use Cookies?

Solimar uses cookies to recognize repeat visits to our websites and to facilitate Web navigation and online shopping. The cookies store your country and language, along with an assigned random session ID. In some cases, the cookies store name and address information so you do not have to re-enter this information in multiple forms.

The cookie information that Solimar collects helps us track the number of visitors to our websites over time and determine whether these were new or repeat visits.

Solimar also works with third-party advertising partners that use cookies to deliver Solimar advertising on other websites and to measure the performance of our advertising campaigns. For example, we use Google Analytics to track website usage and activity. Read more about how Google Analytics uses your information here.

What is a Web Beacon?

A web beacon is an electronic image that can be used to recognize a cookie on your computer or other device when you view a web page or email.

How Does Solimar Use Web Beacons?

Solimar and our third-party advertising partners may use web beacons on our websites, in our emails, and in our advertisements on other websites to measure the effectiveness of our websites and our advertising. For example, web beacons may count the number of individuals who visit our websites from a particular advertisement or the number of individuals who open or act upon an email message.

Can I Block Cookies and Web Beacons?

Yes, the ability to enable, disable or delete cookies can be controlled though your website browser. Consult the “Help” menu of your browser application for details. If you block the use of cookies, you will not be able to use some of the features on Solimar websites. You can make some web beacons unusable by disabling cookies.

Links to Non-Solimar Websites.

Other websites that may be accessed through our website, such as through social media buttons or other links, may collect certain information about you through the use of cookies, web beacons and other features. We do not have access to or control over the cookies or other features that these third-party sites may use, and the information practices of these third-party websites are not covered by this privacy statement. Please review the privacy notices and settings of the third-party site to understand their practices.

Privacy Choices: How Does Solimar Use Interest-Based Advertising?

Websites cooperate with online advertisers to collect information about visitors to present ads that are more useful and relevant. This is known as interest-based advertising or online behavioral advertising. Solimar and our third-party advertising partners may use cookies and web beacons to deliver interest-based ads that are relevant and targeted to our customers and prospects. When delivering interest-based ads, Solimar adheres to the Self-Regulatory Program for Online Behavioral Advertising.

What Information Do Solimar Websites Collect for Interest-Based Advertising?

Solimar and our third-party advertising partners may use cookies or web beacons to collect information for the purposes of interest-based advertising based on your visits to solimarsystems.com and other web sites. These cookies identify the pages you view, the links and ads you click on, other actions you take on those websites, and the referring website. Similarly, online advertisers use cookies to deliver advertising to you for companies other than Solimar based on your visits to solimarsystems.com and other websites.

Solimar may send commercial email to you advertising our products and services. You can also subscribe to various product and service-specific communications on our websites. If you receive commercial email from Solimar and wish to discontinue these mailings, you may unsubscribe via an ‘opt-out’ provided in the communication. You may also mail an unsubscribe request to:

Marketing Privacy Preferences
Solimar Systems, Inc.
Director of Marketing Communications
1515 Second Avenue
San Diego, CA 92101

This unsubscribe option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, software updates, or other administrative and transactional notices, the primary purpose of which is not promotional in nature.

Solimar commits to resolve complaints about your privacy and our collection or use of your personal data.To report your inquiries or concerns to Solimar please contact the Chief Operating Officer at 619-849-2800. You may also contact us via postal mail at:

Solimar Systems, Inc.
1515 Second Avenue
San Diego, CA 92101

If you have questions about Solimar products or services, call us at 1-619-849-2800. More contact information is available on www.solimarsystems.com if you have questions about support, sales, corporate information, or services.

Our Privacy Shield commitment covers human resources information we collect in the context of the employment relationship as well as other personal information that we collect from customers and potential customers. We collect personal information from customers and potential customers through direct email and telephone calls. Additionally, customers and potential customers can contact us on our website regarding our products and services. We may collect some or all of the following information from customers and potential customers located in the EU and Switzerland: name; email address; mailing address; billing address; telephone number; fax number. We use the personal information we collect from our customers and potential customers located in the EU and Switzerland only for legitimate business purposes, including: (1) contract and billing administration, (2) product and service delivery, (3) communications regarding marketing and technical information concerning our products and services, (4) notifying our customers and potential customers regarding product launches and important events related to Solimar Systems, Inc., and (5) fulfilling our business obligations to our customers. The personal information that we collect from our customers and potential customers in the EU and Switzerland is stored in a database that is accessible by certain employees that are located in the United States. We limit access to this information to only those employees who are necessary to carry out the above listed business purposes. We use human resources data we collect from our employees in the UK only for the following business purposes: (1) the management and operations of our company, its functions and activities, (2) employee communications, including employee surveys, (3) maintaining a global directory, (4) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements, (5) development and training programs, (6) recruiting and hiring job applicants, (7) assessing qualifications and performance, (8) performing background checks and verifying references, (9) managing employee performance, (10) determining employee compensation or payment, (11) managing the employee termination process, and (12) other general human resources purposes. The human resources data that we collect from our UK employees is stored in a database that is accessible by certain employees that are located in the United States and by vendors located in the UK. We limit access to this information to only those employees or vendors who are necessary to carry out the above listed business purposes. Solimar Systems, Inc. does not sell personal information to third parties. In certain circumstances Solimar Systems, Inc. transfers personal information to our agents, resellers or third-party service providers (such as accountants, attorneys, consultants, and other service providers). We will transfer personal information only to agents, resellers or third-party service providers who need the information in order to provide services to or perform activities on behalf of Solimar Systems, Inc., including in connection with the delivery of services or products, Solimar Systems, Inc. management, administration, or legal responsibilities. We transfer personal information collected from individuals located in the UK only to third parties in compliance with the Privacy Shield Framework Principals.

Our Privacy Policy may change from time to time. We will post changes to our Privacy Policy in a manner that will make them reasonably easy to find and to understand, as well as to accept or to decline should your approval of such changes be required under GDPR or other regulations. We will also keep prior versions of this Privacy Policy in an archive for you to be able to review.

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