PRIVACY POLICY
Last updated: March 3rd, 2022
Solemma, LLC (“Solemma”, “we”, “us”, “our”) respects privacy and is committed to protecting personal information.
This Privacy Policy (the Policy) informs our customers, business partners, suppliers, service providers and other third parties that we interact with in the course of providing our services, as well as our visitors to our website (solemma.com) (collectively you, your), about how we collect, use, and share personal information.
Important information about this Privacy Policy
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.
To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate that you keep us informed of this so we can amend our records accordingly. By providing us with personal information or using our website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use our website or provide us with your information.
Information We Receive
A. Personal Information
For the purposes of this Policy, “personal information” is any information that identifies or can be used to contact a particular individual. As a business-to-business company, the personal information we typically collect is limited to the information that can be found on a business card—name, organization name, position, address, email address, and telephone number. More specifically, the personal information we collect includes the following categories.
Contact information – first name, last name, email address, position, physical address of your organization, billing address, and telephone number.
Marketing information – details regarding informational and promotional materials you may have requested or received from us, the products in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
Transactional information – details about your organization’s purchases, including method of payment, payments received, payment details, transaction history, and other information relating to your use of our products.
Communications information – copies of communications and inquiries you have submitted to us, including through email, calls, and features available on our website.
Device and usage information – details regarding how and when you use our website and services, including the device used to connect to our website or software, your IP address, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our website.
Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources and information about you that is publicly available.
B. Automatically Collected Usage and Device Information
Like most websites, our website uses various technologies to automatically collect information about visitors. Those technologies include:
Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes. We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our website traffic. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.
Log Files and Device Identifiers. We use log files to track actions occurring on our website and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
Web beacons and other technologies. Our website may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
Analytics. Our website may also use third-party analytics tools such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.
The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may share information about your use of our website with our advertising and analytics partners, who may combine it with other information that you previously provided to them.
C. Information from Other Sources
We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the website, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
D. Social Media
If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable by members or users of our social media accounts. Social media platforms operate independently from Solemma and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
How We Use Personal Information
We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:
Negotiating, entering into, and managing our business relationship and agreements with your company, including providing our services and processing payments from your company.
Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner.
Communicating with you and responding to your inquiries and communicating regarding our services, our agreements with your company, and other issues.
Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
Managing customer service issues, including issues relating to the quality of services and customer feedback.
Developing, updating, and improving our services, customer service, and marketing efforts, and otherwise improving our knowledge and insights regarding customers.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the website.
Enforcing our agreements with customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.
Notifying you about changes to our website or material changes to this Policy.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Choices About Your Personal Information” below.
Our Marketing Efforts
We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.
Disclosure of Personal Information
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
In addition, we may share your personal information with the following types of trusted third parties:
Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf and are obliged not to disclose or use it for any other purpose. Our service providers include (i) IT and system administration providers (ii) marketing and advertising services; (iii) data analytics providers and (iv) payment processors.
Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
Our professional advisors, such as lawyers, accountants, and other similar advisers.
Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
Other parties for any purpose we disclose at the time you provide the information.
Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk. You are responsible for maintaining the confidentiality of the username and password for the services.
Choices About Your Personal Information
We strive to provide you with choices regarding your personal information. If we ever send you promotional emails, you can stop receiving those emails by clicking the “unsubscribe” link in the email. We endeavor to promptly process any unsubscribe requests. You can also correct any personal information you have provided us by contacting us using the information provided below. You can also choose not to provide us with information we may request, but that may result in you being unable to use certain features of our website, request information about our products and services, or initiate transactions with us on behalf of your company.
Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.
International Transfers
Solemma is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations in the United States. To the extent your information was collected outside the United States, you understand and consent that information you provide may be transferred to and processed in the United States. When we transfer personal information to the United States from other countries, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws. Nevertheless, you understand that the data protection laws in the United States may not be the same as the data protection laws in your home country.
EU / U.K. Residents
A. Rights Under the GDPR
The EU’s General Data Protection Regulation and the U.K.’s version of the same (collectively, the GDPR) afford certain rights to individuals in the European Economic Area (EEA). If you are in the EEA, you have the following rights. But not all rights apply in all circumstances.
Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you
Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
With regard to the personal information discussed in this Policy, Solemma is typically the “data controller” for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to privacy@solemma.com. This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity.
B. Lawful Basis
We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.
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Purpose/Activity |
Type of Information |
Basis of Processing |
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To enter into and subsequently to manage our business relationship with you including:
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To administer and protect our business and website including:
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To make decisions about how best to deliver relevant website content and advertisements to you, and to better understand their effectiveness |
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Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site) |
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To advance and promote our business including contacting you regarding services or promotions that may be of interest, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our services, customer service, and marketing efforts |
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Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business) |
C. Transfers from the EU or U.K.
If we transfer personal information from the EU or U.K. to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the EU (such as the United States), we will rely on European Commission’s Standard Contractual Clauses (SCCs) as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors which contain SCCs and define security standards to be employed by each (sub)processors.
Children’s Privacy
Our website is a general audience site and is not directed at, or intended for use by, children under the age of 13 years. Accordingly, we do not knowingly collect personal information from children under age 13. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.
Do-Not-Track Disclosure
Please note that we do not alter our website’s data collection and use practices when we see a “Do Not Track” signal from your device.
Links to Third-Party Websites
Our website may contain links to third-party websites. Such websites have separate privacy policies that you should review. We cannot take responsibility for the content of linked websites or those companies’ data-handling practices.
Changes to this Policy
As indicated above, we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
Contact Us
If you have any questions about this Policy or about how we handle your personal information, then please write to us either by email to privacy@solemma.com or at the following address:
Attn: Privacy Administrator
Solemma, LLC
89 Wendell Street
Cambridge, MA 02138
Phone: (612) 276-2449