Privacy Policy

PRIVACY POLICY

Sollum Technologies Inc.

Last update: 2021-08-24

Sollum Technologies Inc. (“Sollum”, “our”, “us”, “we”), a company specializing in the development and the commercialization of smart LED lighting solutions, takes your privacy and the protection of your personal information seriously. This Privacy Policy (the “Policy”) describes our data protection practices, the types of personal information we may receive or collect from you and of how we use, disclose, store and secure it. By doing so, you will be able to make wise and informed choices.

This Policy applies to our software-as-a-service platform available at https://prod.sollum.tech/login (our “Platform”) and our website available at https://sollumtechnologies.com (our “Website"). However, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on our Platform and Website. These third-party websites have their own privacy policies and we encourage you to read them carefully.

1. PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means any information about an individual that identifies the individual or that, individually or in combination with other information, identifies the individual.

2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

With a legal basis such as your consent

Generally, we will obtain the Personal Information that we need directly from you with your consent, subject to exceptions as provided by applicable laws. For example, Sollum may need to proceed without your consent where, for reasons of fraud detection or prevention, seeking your consent would defeat the purpose. To the extent permitted by applicable laws, Sollum may also rely on other legal grounds, for example, where processing is necessary to comply with legal obligations to which it is subject.

You provide us with Personal Information directly, for example when you use our Platform, our Website or when you communicate with us.

Refusal of collection and withdrawl of your consent

You have the right, if you so choose, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using the Platform or the Website, and accessing our services, as this information is essential to the provision of the requested services.

We would also like to inform you that anonymized information, which does not allow us to know who you are, might be kept even if you withdraw your consent.

Use for secondary purposes

Depending on the circumstances, Sollum may also ask for your consent to use your Personal Information for secondary purposes, such as market research or database purposes. Your consent for secondary use may be withdrawn at any time by contacting us, without affecting the provision of our services to you.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

In the course of our business and service delivery, Personal Information collected may include, but is not limited to:

· Your contact information, such as a name, email address or telephone number in order to identify and correspond with you;

· Your login information such as your email address and password;

· Marketing information and communication preferences such as comments or survey responses;

· Any other Personal Information you have provided to us.

Sollum also collects information relating to the use of its Platform and Website including technical information about your visits, the conversion rate, the average length of a visit, the action carried out on the Platform and the Website, the type of device used, the web browser used during the visit, the IP address, the origin of visitors, or any other information collected through cookies or similar tools. For more information in this regard, we invite you to read the section, “Cookies and other similar tools”.

4. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

Personal Information collected by Sollum may be used for the following purposes:

· To establish and manage our relationship with you;

· To provide and maintain the services requested, namely the access to the Platform and the Website;

· For research and development, statistical purposes and to improve the use of our Platform and Website and your customer experience;

· Respond to your requests for information;

· Respond to your support requests;

· To enable business development and marketing, including informing our current and future customers about our new offerings, with the prior consent of the individual concerned;

· As permitted or required by any applicable legal or regulatory obligation or provision;

· Any other purpose to which you have consented.

5. COOKIES AND OTHER SIMILAR TOOLS

We may use various tools to improve your experience on our Platform and Website, to better understand our customers’ behaviour, and in connection with our marketing strategies. The following section is intended to give you more information about how we use these tools.

Cookies, client-side storage technologies and web beacons

Sollum may use cookies, client-side storage technologies such as Web Storage, IndexedDB or Cache API and web beacons. . In general cookies are small data files that are commonly stored on your device when you use websites and online services. On the other hand, web beacons are tiny images that we may place on our web pages or emails. They can be used, for example, to obtain anonymously the number of times a particular page has been visited by a user or whether an email has been read. As the name implies, web beacons are invisible in any part of our Platform and our Website. Unlike cookies, web beacons are not placed on your computer. For the purpose of this Policy, cookies, client-side storage technologies and web beacons are collectively referred to as “cookies”.

Cookies that we use

Sollum may use different types of cookies. As set forth below, some cookies are strictly necessary to the proper functioning of the Platform and the Website while others are used with you prior consent for functional, performance or advertising purposes.

· Necessary Cookies: We use strictly necessary cookies to enable the proper functioning of our Platform and Website, our security measures and those of third parties. Without these cookies, the services you have requested cannot be provided.

· Functionality cookies (also known as “preference cookies”): These cookies are not essential to the provision of our services. They help personalize and enhance the user experience. For example, if you have consented to their use, such cookies will store your communication and language preferences.

· Performance cookies (also known as “statistical cookies” or “analytical cookies”): These cookies are not essential to the provision of our services. If you have consented to their use, we use performance cookies to understand how you interact with our Platform and Website. Our partners may also use this type of cookie to analyze your use of our Platform and provide us with information about it. These cookies are for statistical purposes only. For more information on our use of cookies, see the “Use of Analytics Tools” section.

· Cookies for advertising purposes: These cookies are not essential to the provision of our services. If you have consented to their use, we use advertising cookies to present you with relevant content, including on social networks. Also, our partners may use these cookies to determine whether our advertisements were displayed to you and whether you interacted with them. In such cases, our partners share data with us, including statistics about the performance of our ads.

Use of analytics tools

If you have consented to their use, Sollum uses analytics tools to analyze the Platform and the Website traffic and usage. Among others, we use the Google Analytics tool offered by Google LLC (“Google”), to collect information about how you navigate our Platform and Website. You can get more information about Google Analytics here.

Targeted advertising

Sollum also works with third-party advertising companies, such as LinkedIn Marketing Solutions, that collect and use information about your visits to our Website in order to present you with advertising that may be of interest to you. Sollum does not share any information that allows advertising companies to identify you.

Social media features

Our Website includes social media features such as the LinkedIn, Facebook or Twitter share button or interactive mini-programs that run on our Website. If you use these features, they collect your IP address, the page you visit on our Website, and create a cookie to enable these features to function properly. These features may be hosted by a third party or directly on our Website.

Deactivation of cookies to which you have consented

Except for strictly necessary cookies, we will only place cookies on your device if you consent to it, and such cookies will be kept for a maximum period of thirteen months from when they are placed on your device. At the end of this period, your consent will be required again.

You can also manage your cookie settings at any time by following the instructions below. However, if you choose to decline cookies, some pages or sections of our Platform and Website may not display properly or some features may not be available. Furthermore, even if you choose not to receive ads targeted to your interests, it is still possible to see ads from Sollum. In this case, they will simply not be adapted to your real needs and may be displayed more frequently.

· Set your preferences on your browser. You can manage your cookie settings by changing the settings on your browser or device. For details on how to set up your browser, please see the help centre for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera.

· Set your social networking selections. If you want to change your settings for sharing cookies via social networks, we invite you to go directly to the sites of these social networks:

o Facebook: https://www.facebook.com/policies/cookies/ ;

o LinkedIn: https://www.linkedin.com/legal/cookie-policy?;

o Instagram: https://www.facebook.com/help/instagram/1896641480634370 ;

o Twitter: https://help.twitter.com/en/rules-and-policies/twitter-cookies.

· Deactivate Analytics. You can deactivate Google Analytics by installing this add-on.

6. HOW DO WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION?

In the course of our business, we may need to disclose and share your Personal Information with various stakeholders as described below:

· Our Employees: In the course of their work, our employees may need to access your Personal Information, for example, when you contact us request support. Their access is limited to what is necessary to perform their duties.

· Agents and Service Providers: From time to time, we may need to share your Personal Information with agents or service providers to help us make the features of our Platform and Website available (e.g., maintenance, analysis, legal requirements, fraud detection, marketing and development). For more information on the transfer of Personal Information, see “Do we transfer your personal information outside of Québec?” section.

· When required by law, to enforce compliance or to protect the property or safety of our rights or those of others: For example, we may disclose Personal Information to legal or regulatory authorities in the event that we suspect money laundering, insider trading, manipulative or deceptive business practices or other criminal activities, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental authorities, regulatory bodies or other self-regulatory organizations. We may also need to disclose Personal Information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).

· Business Transfers: As part of our business development, we may sell or buy businesses or services. In such transactions, Personal Information generally becomes part of the transferred business assets, but remains subject to the promises made in any pre-existing privacy policy (unless, of course, the individual consents otherwise).

· Anonymized: Anonymized Personal Information may be shared with third parties. For example, we may anonymize Personal Information in order to determine trends or statistics.

7. DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF QUEBEC?

The Personal Information that we collect is stored in secure systems hosted on servers that may be located outside your province, territory or country of residence, including in Canada, the European Union and the United States. We may also retain the services of agents and service providers who may be located outside of Quebec.

However, we strive to protect the Personal Information in our custody, including Personal Information entrusted to an agent or service provider, whether located in Canada, the European Union, the United States or other jurisdictions or countries. In particular, we endeavour to limit their access to Personal Information to that which is necessary to perform the tasks they are assigned. Please be aware that we also strive to have contractual agreements in place with these agents and service providers to ensure the confidentiality and security of your Personal Information. This may include implementing robust and effective security measures. If you have any additional questions on this subject, you can contact us.

8. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

Personal Information will be retained only as long as necessary for the fulfillment of those purposes or as required by law for retention periods. As such, the length of time we retain your Personal Information will vary depending on the purpose for which it is to be used. At the end of such period, we strive to destroy or anonymize this information. If you would like more information on this subject, we invite you to contact us. Any user may request that his or her account be deleted by sending a request by email.

9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the Personal Information in our possession. In doing so, we follow generally accepted industry standards. The Personal Information in our possession is therefore only accessible to those persons who have the authority to access it and who consult it only when necessary for the performance of their duties.

Appropriate physical, technical and administrative safeguards and security measures have been put in place and are maintained to minimize the risk of incidents. Example of such measures include restricted access to the physical office and to personal information. If you believe that your Personal Information has been compromised, we invite you to contact us.

10. WHAT ARE YOUR RIGHTS?

Depending on applicable laws, you might have the right to obtain access to, or rectification of your Personal Information, and the right to withdraw your consent (if any). To exercise any of these rights, we invite you to contact us by writing to the address available in the section, “Questions, comments, complaints”.

11. CHANGES AND UPDATES TO THE POLICY

Sollum may, at its discretion, update, revise, modify or supplement this Policy from time to time. If material changes are made to the Policy, you will be notified when you log in and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on our Website. Sollum requests that its users review the revised Policy before continuing to use its Platform and Website.

12. QUESTIONS, COMMENTS, COMPLAINTS

Sollum has established procedures for receiving complaints and inquiries about its Personal Information management policies and practices. We will inform individuals who make inquiries or lodge complaints of the existence of the relevant procedures. Sollum will investigate all complaints. If a complaint is found to be justified, we will take appropriate action including, if necessary, amending our policies and practices. Please feel free to contact us with any questions, inquiries, comments or complaints about your Personal Information. To do so, we invite you to contact us at the following address: info@sollum.tech

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