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

December 2016

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

This Privacy Policy covers and describes how Solium collects, uses and the disclosure of information we collect through our website www.solium.com and our service Shareworks®. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client (i.e. the Participant) has engaged Solium.

Solium has developed this privacy policy for our users of our public website and users of our Shareworks platform. These guidelines deal with the rights of individuals to have access to their personal information and to have it corrected, if necessary, as well as the ways in which Solium collects, uses and discloses personal information. Using PIPEDA as a guide, personal information includes any factual or subjective information, recorded or not, about an individual but does not include the name, title or business address or telephone number of an employee of an organization.

TRUSTe

Solium complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from  Switzerland. Solium has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Solium’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.

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

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

Collection of Information and Use

We collect the following information from you: name, email address, address and phone number. We use this information solely to respond to customer service request, administer your account and assess your fit and desire for additional Solium products and services. For greater certainty this use does not apply to any third party products or services.

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 and/or reply to your requests 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 or our immediate partners. We may use your email address to send you information about our business and services that may be of interest to you. If you do not wish to receive this type of material you may unsubscribe at any time by following the instructions provided in the communication. 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.

Information Sharing

We will share your personal information with third parties only in the ways that are described in this privacy policy.

We may also disclose your personal information:

  • 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 information, as well as any choices you may have that arise regarding a change in use of your personal information;
  • to any other third party with your prior consent to do so, which consent may be withheld in your sole discretion.

Cookies and other tracking technologies

When you visit our website and view/read pages, or download content onto your computer, Solium uses cookies 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 policy. We do not have access or control over these cookies.

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, which does not identify individual users, 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 greater Solium 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. Once you log into the Shareworks platform, 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 from 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.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. However, for greater certainty, if you are an employee of one of our corporate clients we shall act in accordance with the terms and conditions in our agreement with your employer. If you have any questions about security on our website, you can contact us using the contact information below.

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).

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.

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.

Links to Other Websites

Our site includes links to other websites whose privacy practices may differ from those of Solium. If you submit personal information 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, such as the Share this button or interactive mini-programs that run on our site. 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. Social Media Features and Widgets 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 policy of the company providing it.

Updating Your Personally Identifiable Information

All personal information is accessible through your personal account with Solium. Upon request Solium will provide you with information about whether we hold any of your personal information. You may access this information through our website or by contacting us directly by using our contact information below. You may verify the accuracy and completeness of your information, and request amendments or deletion to this information if required. We will respond to requests for access of personal information as soon as reasonably possible and in any event within 30 days.

Data Retention

Subject always to all applicable laws and regulations and, if you are an employee of one of our corporate clients, the terms of our agreement with your employer, we will retain your information and the data we process on the Shareworks Platform for as long as your account is active or as needed to provide you services. If an individual wishes to request that we no longer use your information to provide you services contact us using the contact information below and the request will be reviewed. Subject always to all applicable laws and regulations and, if you are an employee of one of our corporate clients, the terms of our agreement with your employer, we will retain and use your information as is strictly necessary to comply with our legal obligations, resolve disputes, as well as comply with and enforce the General Conditions for Use of the System, and our agreement with your employer, if applicable.

Notification of Privacy Policy Changes

We may reasonably update this privacy policy 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 Policy then prior to such change becoming effective, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Solium Web site.

Contact Information

You can contact us by writing or email us at the addresses below:
1500, 800 – 6th Ave SW
Calgary, Alberta, Canada
T2P 3G3
compliance@solium.com

Privacy for Shareworks Platform Users

Solium’s privacy policy complies with the Canadian federal government’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the Alberta provincial government’s Personal Information Protection Act (PIPA). PIPEDA incorporates the ten privacy protection principles that form the Canadian Standards Act (CSA), which has been titled the Model Code for the Protection of Personal Information. The CSA deals with the rights of individuals to access their personal information and have it corrected, if necessary, as well as the ways in which an organization collects uses and discloses personal information.

This privacy policy supplements Solium’s General Conditions for Use of System.

Solium’s Eleven Privacy Protection Principles

  • Accountability – All employees of Solium are required to follow the standards set out in this Privacy Policy, and are 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 information.
  • Purpose for Collection of Personal Information – The personal information we collect and use is limited to what is required to provide the entitlement plan administration services offered by Solium and to provide any other services requested by you.
  • Consent – Consent for collection, use and disclosure of your personal information is obtained when an account is opened with Solium and you signify acceptance of Solium’s General Conditions for Use of System.
  • Limiting Collection – Personal information collected is strictly limited to what is required to administer employee entitlement plans, the services provided within this administration, and to provide any other services requested by you. We will collect this information from your completed activation form, and from the details provided to us by you or your employer.
  • Limiting Use, Disclosure and Retention – The use of personal information we collect is limited to: (a) what is required to provide the employee entitlement plan administration services as outlined by Solium; and (b) use by Solium in order to offer and provide ancillary product and service offerings related to (a) above. Such personal information shall not be used or disclosed for any other purposes. The collection of a Government-issued identification number is only mandatory in instances where law requires it, such as for tax reporting purposes. All personal information collected is maintained in a highly secure environment and is kept strictly confidential and would only be disclosed to outside parties when authorized by you, when required by law, or when permitted by law. Your personal information is retained only as long as necessary, for the purposes of recordkeeping and administration of employee entitlement plans, in accordance with all applicable laws and regulations. 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.
  • Accuracy – Solium makes every effort possible to ensure the information we collect from you and your employer is complete, accurate and up-to-date. All personal information collected is available for you to view when you access your Solium account.
  • Service Provider, Sub-Processors/Onward Transfer – Solium may transfer personal information to companies that help Solium provide its products and services that relate to your employee entitlement plans. Any transfer to a third party is covered by the provisions of this Policy and, if relevant, the terms of our agreement with your employer.
  • Safeguards – Solium has implemented strict procedures to protect the data stored within our infrastructure. Our data is housed at a secure offsite location with tight physical and electronic security access. All access and collection of personal information within our site requires a 128-bit encrypted browser, to ensure the highest commercial level of security for your Internet transactions. If you contact a Solium Client Services Representative by phone, you will be asked to provide your personally selected verification word and/or some other personal identification information.
  • Openness – Our privacy policy is available to view on our site at any time, or you may request information from us about our policies and practices related to the management of your personal information.
  • Client Access – All personal information 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 this information if required.
  • Client Complaints and Suggestions – You may direct any inquiries regarding the above privacy principles or our practices by contacting us and speaking to the Privacy Officer who is accountable for our privacy and practices policies at Solium (See contact information above).

Use of Third Party Suppliers

Solium may use third-party providers to perform certain services on our behalf such as printing, mail distribution, or data processing. These parties are only given the information necessary to strictly 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.

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.