Solium Privacy Statement

Protecting your privacy and safeguarding your personal, business and financial information is a key priority at Solium.

Effective May 24, 2018

Solium® Capital Inc. (together with its affiliates, “Solium”) is dedicated to conforming to applicable privacy standards that have been established by industry bodies as well as applicable laws and regulations.

This Privacy Statement covers and describes how Solium collects, uses, discloses and otherwise processes personal data we collect through our website, www.solium.com and through our service Shareworks®.

TRUSTe

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Privacy Statement for Solium Website Users

This Privacy Statement describes how Solium handles information collected from you when you visit our website. If you have questions about your privacy protection, please contact us, at the contact information below.

Collection of Information and Purpose of Collection

General

We collect personal data from you when you request information regarding our products and services, download a document, demo a product or service, or request a product or service quotation. The personal data we collect in those circumstances includes name, email address, postal address and phone number.  We collect this information solely to provide you with the requested information and to conduct related marketing and audit activities. For greater certainty, this use does not apply to any third-party products or services. The legal basis for our processing this personal data is Solium’s legitimate interest in marketing and promoting our products and services, which is not overridden by your data protection interests.

Email Subscriptions and Interaction

When you sign up for a Solium electronic communication service, email us, or ask us to respond to you via email through our website www.solium.com, Solium records your exact email address and any information you have included in your electronic submission (an “Information Request”). We use your email address to acknowledge your comments, to reply to your requests, and/or to conduct audit activities and we will store your communication and our reply in case we correspond further. We will not communicate your email address to anyone other than our affiliates. If you have subscribed to receive information about Solium on a regular basis, you may also unsubscribe for this service using the instructions in the regular email submission.  The legal basis for our processing this personal data is either that you have consented to such processing as part of your Information Request and/or Solium’s legitimate interest in marketing and promoting our products and services, which is not overridden by your data protection interests.

Responding to Surveys

When you respond to a survey question, Solium may use your submission for the purpose of processing survey results, and we may publish those result aggregates on our website provided always that you are not in any way personally identifiable. We may use your response to improve our website or our products and services and may follow up with you to provide any further information about our related products or services. Based on the question personal data may or may not be collected.  In the instances that personal data is collected, the legal basis for our processing this personal data is Solium’s legitimate interest in marketing, improving and promoting our products and services, which is not overridden by your data protection interests.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your prior express written consent we may post your testimonial along with your name, which is our legal basis for processing such data.

Information Sharing

We will share personal data with third parties only in the ways that are described in this Privacy Statement. If you do not want us to share your personal information with these companies, contact us at privacy@solium.com.

We may disclose personal data:

  • To another entity in the Solium corporate family of affiliates;
  • In certain situations, Solium may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • As required by law, such as to comply with a subpoena, or a government request or similar legal process;
  • When we reasonably believe in good faith that disclosure is genuinely necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. At all times where we disclose your information pursuant to this provision, we will take all steps reasonably necessary to ensure that it remains secure
  • To a successor to Solium that purchases Solium’s business, in which case you would be notified of such a change if it manifests in any material change of use of your personal data, as well as any choices you may have that arise regarding a change in use of your personal;
  • To any other third party with your prior consent to do so, which consent may be withheld in your sole discretion.

Data Transfers

As part of the information sharing with Solium affiliates and third parties, Solium may transfer this personal data to the country in which the affiliate or third party is located.  For transfers of personal data of EU residents to affiliates and third parties located outside of Canada, this is done pursuant to onward transfer agreements with the relevant Solium entity and/or pursuant to the Standard Contractual Clauses executed with that third party. Please note that for transfers of personal data of EU residents to Canada, adequacy has been established by the EU Commission.

Data Storage

We will store your personal data only for as long as necessary to fulfill the purposes for which Solium collected it, including retaining it for as long as we believe our legal bases are valid to continue such retention.

Updating, Restricting or Deleting Personal Data

Upon request, Solium will provide you with information about whether we hold any of your personal data and what data we hold. You may request this information by emailing us at compliance@solium.com or by sending us the request using our physical address below. As part of these requests, you may verify the accuracy and completeness of your information, and request amendments or deletion to this information if required. You may also request the restriction of processing of your personal data in the event legal obligations prevent Solium from deleting your personal data. You have the right to object to processing based on Solium’s legitimate interests. We will respond to requests for access, deletion or restriction of processing of personal data as soon as reasonably possible and in any event within one (1) month of receipt of your request.

Withdrawal of Consent, Objection and Restriction of Processing

Where the processing of your data is based on your consent, you have the right to withdraw your consent to data processing activities at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Complaints with the EU Data Protection Authorities

EU Residents have the right to lodge a complaint with the data protection supervisory authorities of the EU member state where your data has been processed by Solium.

Cookies and other tracking technologies

When you visit our website and view/read pages, or download content onto your computer, Solium uses cookies and other tracking technologies to ascertain which pages are visited, what content is chosen for use, and which websites you visited immediately before coming to our site. Unless you have made an Information Request, this information is not associated with you as an individual, but is used in aggregate to monitor our site’s performance. We record these statistics to help us understand what type of information is most useful to our audiences and to make it easy for users to find this information. Our partners, affiliates, tracking utility company and service providers use cookies to make it easier for you to navigate our site. The use of cookies by our partners, affiliates, tracking utility company, and service providers is not covered by our Privacy Statement. We do not have access or control over these cookies. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Our Web pages contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

Analytics / Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

We do link this automatically-collected data to personally identifiable information. These logs are used for audit purposes of the Shareworks application.

Behavioral Targeting / Re-Targeting for Advertising

We partner with a third-party ad network(s) to either display advertising on our website or to manage our advertising on other sites for the Solium corporate family’s business needs. Our ad partner uses cookies and web beacons to collect non-personally identifiable information about your activities on our website and other web sites to provide targeted advertising. Note that this is for any person who comes to the Solium website regardless of purpose, as we cannot in advance determine the purpose of a website visit. This kind of activity is done by and on behalf of virtually all commercial websites in order to optimize business effectiveness on the Internet and shall be carried out always in accordance with all applicable laws and regulations. Please note that for individuals using our Shareworks platform, once you log in, we do not track your activity in Shareworks for the purposes of any advertising.

If you wish to not have your non-personably identifiable information tracked by the Solium website and used for the purposes of serving targeted ads, you may opt-out by clicking here (or if located in the European Union click here), in which case Solium will not participate in, or cooperate with, third-parties for the purposes of directing advertising to you. This procedure is the standard commercial practice on the Internet for managing an individual’s preferences and is managed by TRUSTe on behalf of Solium. Please note that this does not opt you out of being served advertising that is directed and controlled by other parties on the Internet like search engine companies and/or other organizations with access to your Internet activity. For greater certainty, Solium’s opt out is for your interface with Solium only and not any opt out related to the Internet or advertising in general.

Local Storage Object

Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Confidential Transmission

Email sent over the Internet is generally unencrypted. If Solium requests that you transmit confidential information to us over the Internet, we ensure that such transmission is encrypted. If you wish to provide us information electronically by email on our website and would like to ensure its confidentiality, please contact us, see contact information below.

Safeguards

The security of your personal data is important to us. We protect the personal data submitted to us, both during transmission and once we receive it, using appropriate administrative, physical and technical safeguards and following generally accepted industry standards. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Links to Other Websites

Our site includes links to other websites whose privacy practices may differ from those of Solium. If you submit personal data to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Widgets

Our website may include Social Media Features, such as the Facebook Like button and widgets, the Share this button or interactive mini-programs that run on our site (collectively, “Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Features are either hosted by a third party or hosted directly on our site. Your interactions with these Features, if any, are governed by the Privacy Statement of the company providing it.

Notification of Privacy Statement Changes

We may reasonably update this Privacy Statement to meet legislative and risk challenges of our industry and industry standard practices, provided reasonable notice has been given to you. Without prejudice to our other obligations to you, if applicable, if we make any such change in this Privacy Statement then prior to such change becoming effective, we will notify you by means of a notice on the Solium website.

Contact Information

You can contact us by writing or emailing us at the addresses below:
Solium Capital, Inc.

Attn: Compliance

Suite 1500 – 600 3rd Ave SW
Calgary, Alberta T2P 0G5

compliance@solium.com

 

Privacy Statement for Shareworks Platform Users

The information set forth below should help you to understand how Solium processes personal data. When Solium processes personal data for data subjects on its Shareworks® platform, it does so as a data processor. Your employer is the data controller. This Privacy Statement for Shareworks Platform Users supplements Solium’s General Conditions for Use of System.

Accountability – All employees of Solium are required to follow the standards set out in this Privacy Statement for Shareworks Platform Users, as well as Solium’s Global Privacy Policy. They are also required to sign a confidentiality and non-disclosure agreement as a condition of their employment. Only employees who have been authorized and have a legitimate business purpose can access confidential personal data.

Purpose for Collection of Personal Data – The personal data we collect and use is limited to what is required to provide the plan administration services offered by Solium and to provide any other ancillary product and service offerings related to the services requested by your employer (the “Services”).

Consent – Since your employer is the data controller, it is responsible for determining the legal basis for processing and obtaining your consent thereto, as appropriate.  From Solium’s perspective, your consent for collection, use disclosure and other means of processing of your personal data is obtained by your employer in advance of the time that your account is created in Shareworks.

Limiting Collection – The personal data collected is strictly limited to what is required to provide the Services. We will collect personal data from the details provided to us by you or your employer.

Limiting Use, Disclosure and Retention – Use of the personal data we collect is limited to what is required to provide the Services. Such personal data shall not be used or disclosed for any other purposes. A Government-issued identification number is only collected in instances where it is required by law or required to provide the Services, such as for tax reporting purposes.

We will share personal data with third parties only in the ways that are described in this Privacy Statement.

We may disclose personal data:

  • To another entity in the Solium corporate family of affiliates;
  • In certain situations, Solium may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • As required by law, such as to comply with a subpoena, or a government request or similar legal process;
  • When we reasonably believe in good faith that disclosure is genuinely necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. At all times where we disclose your information pursuant to this provision, we will take all steps reasonably necessary to ensure that it remains secure
  • To a successor to Solium that purchases Solium’s business, in which case you would be notified of such a change if it manifests in any material change of use of your personal data, as well as any choices you may have that arise regarding a change in use of your personal;
  • To any other third party to assist us in our data processing, but only with your employer’s prior consent to do so. Examples of when we request such disclosure to third-parties is when we require their assistance for printing, mail distribution, or tax slip production. These parties are only given the information necessary to perform the particular service. Solium requires that any third-party service provider protect your information in a manner that is consistent with our privacy policies. However, in the event our service provider is located in a foreign jurisdiction, they are bound by the laws of the jurisdiction in which they are located and may be required to disclose information in response to valid demands from regulators, courts, government authorities, or law enforcement authorities and, if relevant, Solium shall otherwise comply with the terms of the agreement with your employer.

As part of the information sharing with Solium affiliates and third parties, Solium may transfer personal data to the country in which the affiliate is located.  For transfers of personal data of EU residents to affiliates located outside of Canada, this is done pursuant to onward transfer agreements with the relevant Solium entity or third party. Please note that for transfers of personal data of EU residents to Canada, adequacy has been established by the EU Commission.

If you elect to opt out of the sharing of your information among the Solium affiliates, please email us at privacy@solium.com indicating your preference of “Do not share my information” in the subject line of your email.

Your personal data is retained only as long as necessary: (a) for the purposes of providing the Services, (b) in accordance with all applicable laws and regulations, (c) to resolve disputes, and (d) to comply with and enforce the General Conditions for Use of System and our agreement with your employer.

If you request that we no longer use your personal data to provide you with the Services, contact us using the contact information listed below and the request will be reviewed.

Accuracy – Solium takes reasonable measures to ensure the information we collect from you and your employer is complete, accurate and up-to-date. All personal data collected is available for you to view when you access your Solium account.

Service Provider, Sub-Processors/Onward Transfer – Solium may transfer personal data to third parties that help Solium provide the Services. Any transfer to a third party is covered by the provisions of this Privacy Statement and, if relevant, the terms of our agreement with your employer.

Security – Solium has implemented appropriate administrative, physical and technical safeguards that follow generally accepted industry standards to protect the personal data stored within our infrastructure, as well as during transmission. Our data is housed at a secure offsite location with appropriate physical and electronic security access. All access to and collection of personal data within our site requires a 128-bit encrypted browser to ensure security for your Internet transactions. If you contact a Solium Client Services Representative by phone regarding your Shareworks account, your identity will be verified by the Representative. When you enter sensitive information on our site (such as log in credentials), we encrypt the transmission of that information using secure socket layer technology (SSL).

Openness – This Privacy Statement is available to view on our website at any time, or you may request information from us about our policies and practices related to the management of your personal data.

Client Access – All personal data that we collect about you is accessible through your personal account with Solium. You may access this information through our website or by contacting us directly. You may verify the accuracy and completeness of your information, and request amendments to such information, if required.

Client Complaints and Suggestions – You may direct any inquiries regarding our Privacy Statement by contacting us at compliance@solium.com.

Notification of Privacy Statement Changes

We may reasonably update this Privacy Statement to meet legislative and risk challenges of our industry and industry standard practices, provided reasonable notice has been given to you and your employer. Without prejudice to our other obligations to you and your employer, if applicable, if we make any such change in this Privacy Statement then prior to such change becoming effective, we will notify you either by email (sent to the email address specified in your account) and/or by means of a notice on the Solium website.

Contact Information

You can contact us by writing or emailing us at the addresses below:
Solium Capital, Inc.

Attn: Compliance

Suite 1500 – 600 3rd Ave SW
Calgary, Alberta T2P 0G5

compliance@solium.com