Privacy Policy

Last Updated July 22, 2019

Soleo is committed to handling any information it collects, that can be used to directly or indirectly identify you (“Personal Information”), in a responsible manner and securing it through administrative, technical and physical safeguards.  To that end, we have developed the following policy (“Privacy Policy” or “Policy”) to be transparent about what Personal Information we collect, maintain, and use. The language in our Policy is easy-to-understand in order to help you make informed choices about your Personal Information and to provide you with control over the Personal Information you provide to us.

Soleo Communications, Inc. (“Soleo”, “We”, “Us”, or “Our”) provides a call management platform which includes access to its pay-per-call advertising network. Our products and services are targeted and marketed to businesses and not directly to consumers. This Privacy Policy describes Soleo’s privacy practices and the way in which we may collect, use and secure the Personal Information you (“Customer”, “You”, or “Your”), provide to us while using the Service via Soleo.com and any associated Soleo platforms, sites or mobile applications.  This includes how we handle such information, how we protect the security of such information, and how you may change or request that we remove such information from our systems. We will not, except as described in this Privacy Policy, disclose, sell, rent or otherwise provide to any third-party any Personal Information collected from you.

In the event this Privacy Policy conflicts with a privacy policy provided for on any other Soleo webpage, site, or platform, this Privacy Policy will control. This Privacy Policy is expressly incorporated into Soleo’s Terms of Service, which apply to your use of the Service. BY USING THE SERVICE, YOU CONSENT TO THIS PRIVACY POLICY AND TO OUR RECEIPT, RETENTION, DISCLOSURE AND PROCESSING OF YOUR PERSONAL INFORMATION FOR THE PURPOSES STATED IN THIS POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT REGISTER FOR OR USE THIS SERVICE, AND NAVIGATE AWAY FROM OUR SITE.

1. DESCRIPTION OF SERVICES.

Soleo offers a call management platform that includes access to our pay-per-call advertising network. Features of the Service include, but are not limited to: number assignment and porting, call tracking, call forwarding, custom call routing, Interactive Voice Response (“IVR”) menu creation, voicemail, call recording, call transcription, dispute handling, real-time dashboard reporting, lead generation, campaign management tools, and a variety of plug-ins and integrations with third-parties (the “Service”). 

2. HOW DOES SOLEO COLLECT PERSONAL INFORMATION?

Soleo may collect Personal Information when you call any of the phone numbers associated with our business or support lines, while you are searching through any of our sites, when you register for the Service, when you add or change account information, including credit card or other payment information, when you interact with the Service by phone, online or via our mobile application, or when  you interact with any third-party sites or applications that are linked to the Service. Soleo uses a secure third party to collect and store your credit card or other payment information. On occasion we may ask you to provide information based on your experience using the Service. This is a voluntary feedback process and any information you provide to us will be used solely to measure and improve the quality of the Service.

Any callers placing phone calls to any phone numbers that Soleo provides to you as part of the Service should be aware that they are placing calls to phone numbers supplied by Soleo and they could be disclosing Personal Information during those calls on an unsecured line. Our Privacy Policy and the security measures we have in place are not meant to cover these types of disclosures of Personal Information from the callers. Callers should be aware that they are solely responsible for any disclosures of Personal Information they may make during any call placed to one of these phone numbers supplied as part of the Service. You are responsible for communicating this information to your callers.

Additionally, as part of the Service, Soleo or you may create other information gathering tools to collect certain Personal Information from your callers or clients when they interact with features of the Service. Soleo will collect and handle that information as set forth in this Privacy Policy. However, Soleo shall not be liable to any of your callers or clients as it relates to your collection or use of such Personal Information; your own privacy policy shall govern your obligations and liabilities as to your callers or clients.  

3. CALL RECORDING AND TRANSCRIPTION SERVICES.

As part of the Service, Soleo provides unique phone numbers for Customer(s) to use for marketing other business-related purposes. Soleo may collect information when the caller places a call to a phone number that is associated with the Service. Such information may include the caller’s name, address, location, and other personally identifiable information. Additionally, Soleo offers call recording and transcription features as part of its Service. Soleo may listen to the call recordings or review the call transcripts to make improvements to the Service, or to resolve a dispute with you related to the quality of such call. Soleo will play an announcement to the caller at the beginning of the call notifying them that the call may be recorded and/or monitored. Again, Soleo shall not be liable to any of your callers or clients as it relates to your collection or use of such Personal Information provided on these call recordings or transcripts; your own privacy policy shall govern your obligations and liabilities as to your callers or clients.

4. WHAT INFORMATION DOES SOLEO COLLECT?

Soleo may collect Personal Information from you or your callers or clients who call any numbers you purchased through the Service. Such Personal Information may include:

  • name;
  • name of your business;
  • phone number;
  • phone number of your business;
  • email address;
  • email address of your business;
  • hours of operation of your business;
  • geolocation information;
  • credit card, debit card, bank account or other payment information that you provide to arrange for payment of the Service, directly or indirectly, through our sites;
  • other details about your business in connection with the creation of your account and your use of the Service, specifically if you are purchasing leads from Soleo: your target markets and budget for lead generation services;
  • correspondence between you and Soleo;
  • survey results;
  • lists of products or services ordered by you from Soleo;
  • information to validate your identity in case you forget a password or username;
  • device-specific information (for example: tablet model, mobile phone model, operating system version, and mobile network information including phone number);
  • ISP;
  • browser type and version;
  • IP address;
  • what pages, reports, widgets, and other tools you used in relation to the Service;
  • any unusual event information such as crashes, errors, slow load times, and other troubleshooting details; and/or
  • other information produced by Cookies or Web Beacons.

5.  WHAT ARE COOKIES AND WEB BEACONS? HOW DOES SOLEO USE THEM?

A Cookie is a small piece of data sent from a website and stored locally on your computer by your web browser while you are browsing on a site on the internet.  Cookies enable Soleo, and third-party sites, to recognize you or your preferences, gain information about your use of the Service, enhance your user experience, and help us to improve our Services. Some Cookies are automatically deleted at the end of a web session, however, Soleo may use persistent Cookies that remain on your browser after your session is terminated. Some Cookies may provide an opt out option. Soleo does not maintain a process to track opt out related to Cookies. However, the ‘Help’ option on the toolbar of most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive a new Cookie, or how to disable Cookies altogether.

A Web Beacon is similar to a Cookie. A Web Beacon is embedded on a specific website instead of being stored locally on your computer. Web Beacons are used to track your online behavioral movements and internet use. Soleo may use Web Beacons in some of its marketing or promotional materials that it sends to you. We do this by embedding a Web Beacon in the email or landing page we send to you. We can determine who opened or viewed certain messages or landing pages, and in turn improve the quality of our marketing efforts. You can opt out from receiving these messages by clicking the ‘unsubscribe’ link in any marketing communications. 

6. WHY DOES SOLEO COLLECT PERSONAL INFORMATION?

We may collect and use your Personal Information for the following purposes:

  • to communicate with you about the Services we provide;
  • to provide you the Services you register for;
  • to customize aspects of our Service to fit your needs;
  • to maintain, improve, and provide basic functionality of the Service;
  • to resolve any support tickets or service requests;
  • to send you information on promotions or events;
  • to send you newsletters, blogs, white papers, or other information you may be interested in; and
  • to transmit information to Soleo’s third-party payment processor for the purpose of completing one or more payment transactions.

7. WILL SOLEO DISCLOSE PERSONAL INFORMATION?

Except as provided in this Privacy Policy, Soleo will only use your Personal Information as it relates to the Services you request from Soleo. Soleo will not sell, rent, trade, or otherwise disclose or transfer any Personal Information to any third party without your explicit permission, unless, in its sole and reasonable discretion Soleo believes that one or more of the following conditions applies:

  • you have given us your permission to disclose the Personal Information;
  • to transmit information to Soleo’s third-party payment processor for the purpose of completing one or more payment transactions;
  • the disclosure is made to a party that controls or is controlled by Soleo;
  • the disclosure is made to a vendor that has been retained by Soleo to provide certain services, including, but not limited to, maintenance or performance improvement to any of Soleo’s systems or platforms, marketing services, or data analysis; 
  • the disclosure relates to the acquisition or sale of certain assets, subsidiaries, or business units between Soleo and another entity. In the event of such transactions, Personal Information collected through the Service may be one of the transferred business assets. We reserve the right to include Personal Information in any such transfer;
  • the Personal Information is otherwise publicly available;
  • to satisfy a valid order from any court or governmental agency, or to comply with any applicable law or regulation. Soleo will provide reasonable assistance and information, including Personal Information, to any appropriate judicial, law enforcement or government authorities that make a lawful request for such information, and you hereby consent to such disclosure;
  • to prevent or investigate any potential illegal activity, regardless of the existence of a subpoena, warrant or other valid court order;
  • to enforce or investigate violations of the Terms of Service; and/or
  • to protect the rights, property or safety of Soleo, its users or the general public.

8. CAN I OPT OUT FROM PROVIDING PERSONAL INFORMATION?

You must provide your Personal Information in order to do business with Soleo, however, providing such information is purely voluntary. If you do not wish to provide Personal Information simply decline or terminate contact with Soleo, its sites and the Service. Please note, if you do not wish to provide certain Personal Information it may limit your ability to use the Services Soleo is able to offer to you. Soleo’s primary intent in collecting and using the Personal Information you provide to us is to deliver the Services you request. Soleo may use your Personal Information to communicate with you in relation to the Service, or on rare occasions to send you information related to any planned or unplanned Service outages. You do not have the option to opt out of such communications as they are tied directly to the Service. Additionally, Soleo may also use the Personal Information collected for marketing and other communication purposes. If you wish to opt out of receiving such marketing related commutations simply click the ‘unsubscribe’ link in the promotional communication.  

9. HOW DOES SOLEO PROTECT YOUR PERSONAL INFORMATION?

Soleo undertakes various precautionary measures to maintain the security of the Service, its sites and your Personal Information. Your Personal Information is stored on secure servers at secure locations. Soleo protects your Personal Information online by ensuring that our third-party hosted server provider(s) and credit card processor(s) use industry standard encryption methods to prevent unauthorized access to your Personal Information that is stored on our servers. Soleo protects your information off-line by restricting access to your personal information in its facilities through implementing and enforcing administrative access policies. Your Personal Information can only be accessed by authorized personnel, as designated by Soleo, that require access to this data in order to fulfill their duties.

However, you should be aware that the nature of the Internet is such that we cannot guarantee or warrant with absolute certainty the security of any Personal Information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take commercially reasonable steps (including appropriate technical and organizational measures) to protect your Personal Information.

Soleo may store and process your Personal Information in any state or country in which Soleo maintains facilities, including outside of the state or country from which such consent to obtain Personal Information first originated. The privacy laws in the jurisdiction where your Personal Information is stored may be different from the privacy laws where you live. If you are located outside the United States and choose to provide information to us, please be aware that we transfer Personal Information to the United States and process and store it there. As a result, your information may be subject to access requests from governments, courts, and/or law enforcement officials in the United States. By using the Service and accessing any of our sites, you consent to the transfer of information outside of your state and/or country.

10. WHAT ABOUT LINKS TO THIRD-PARTY SITES AND/OR APPLICATIONS?

This Privacy Policy applies solely to information that is acquired by Soleo through the Service or any of its platforms or sites. The Service may include links to third-party websites neither owned nor managed by us. Additionally, if you use any plug-ins associated with the Service, these applications or platforms may obtain your Personal Information. Soleo does not and cannot control how third-party sites may obtain or use your Personal Information. Soleo does not review the privacy policies of any third-party sites. We cannot guarantee the privacy of any Personal Information that may be obtained by third parties at or through these other websites. We strongly encourage you to review the privacy policies of any website you visit before supplying your Personal Information through that site. Soleo accepts no responsibility or liability for the practices of any third-party sites.

11. SOCIAL MEDIA PLATFORMS AND OTHER PUBLIC FORUMS.

Soleo’s Service and sites include Social Media features and other widgets, such as ‘Like’ or ‘Share’ buttons that may interact with various third-party sites. When you interact with any of these features you may be disclosing Personal Information to a third-party, and any such interaction or disclosure will be governed by the privacy policy of such Social Media platform or other third-party site.

Soleo provides publicly accessible blogs and forums on its sites. Any information provided on a blog or open discussion forum available on any Soleo site may be read, collected and/or used by any other person or entity accessing our sites. To request the removal of anything you have posted to one of our blogs or online forums controlled by Soleo please email legal@soleo.com. We will respond to your request within a reasonable timeframe.

12. CAN THIS PRIVACY POLICY BE MODIFIED?

Soleo reserves the right to modify the provisions of this Privacy Policy as Soleo believes necessary or appropriate at any time. It is your responsibility to regularly review this Privacy Policy. However, if Soleo makes a material change to this Privacy Policy, we will inform you by email or by posting a notice on our site. Any revised versions of this Privacy Policy shall be effective immediately upon posting. You agree that your continued use of the Service following such notification or posting shall constitute your acceptance of the revised Privacy Policy.

13. HOW LONG IS YOUR PERSONAL INFORMATION RETAINED BY SOLEO?

Unless you request that Soleo delete your Personal Information, Soleo will retain your Personal Information for as long as necessary to (i) fulfill any obligations consistent with any purpose identified in this Privacy Policy or in the Terms of Service or (ii) comply with any applicable law or valid order from a government agency, court of competent jurisdiction, or other law enforcement official. Soleo may, but is under no obligation to, periodically review Personal Information in its possession and dispose of Personal Information of its Customers that (i) are no longer using the Service, (ii) have not accessed the Service for a substantial period of time, or (iii) Soleo, in its sole discretion, believes is no longer current or accurate.

Please note, if you cancel your account, or if your account is terminated for any reason, Soleo provides no guarantee that your data or Personal Information will remain available if you wish to commence Service again at a future date. Soleo provides no backup files once your Personal Information has been deleted.

14. HOW CAN YOU ACCESS YOUR PERSONAL INFORMATION?

You have the right to access and amend your Personal Information. You may inform us of any changes to your Personal Information and we will update or delete your Personal Information accordingly. Soleo will use reasonable efforts to accommodate any requests to delete your Personal Information, unless it is required to be retained by law or for any lawful business purpose consistent with this Privacy Policy and the Terms of Service. You may edit some of your own Personal Information online through your account settings. If you would like details on the Personal Information Soleo maintains about you or to have any Personal Information updated or deleted please contact your Soleo Account Management representative, or if you don’t have a dedicated representative please contact legal@soleo.com. Soleo will respond to any such requests within a reasonable timeframe.

Soleo does not target or direct its Service directly to consumers (e.g. your callers). The Service we provide is a business to business solution. Therefore, if a consumer seeks to access, or otherwise update or delete his/her Personal Information that Soleo may have on file, then that consumer should contact you and refer to your privacy policy for such procedures. However, if a consumer does direct an inquiry related to their Personal Information to Soleo, we will notify you and respond to any such requests within a reasonable timeframe. 

15. AGE RESTRICTIONS AND THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT.

You must be at least 18 years old to access our sites and register for the Service. Soleo does not target our Services to children. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this site, register for Service, make any purchases through the site, use any of the interactive or public comment features of this site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13, without verification of parental consent, we will delete that Personal Information.

If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us at legal@soleo.com and we will use our best efforts to respond to your request and delete any Personal Information within a reasonable timeframe.

16. CALIFORNIA RESIDENTS AND THE CALIFORNIA CONSUMER PROTECTION ACT.

Soleo’s Service and platforms are a business to business solution. Our Services are not marketed directly to consumers. However, in the event a consumer in California happens to interact with our sites or Services, and assuming the CCPA is applicable, then the consumer [California resident] may opt-out from allowing us to disclose Personal Information about them to third parties for marketing purposes. If a consumer [California resident] wishes to opt out, they may do so by contacting legal@soleo.com. Additionally, residents of California have the right to request, from a business with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for marketing purposes and identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of such information, please contact us at legal@soleo.com. We will respond within 30 days as required under California law.

17. EUROPEAN UNION RESIDENTS AND THE GENERAL DATA PROTECTION REGULATION.

Controller and Processor Role

Pursuant to the GDPR Soleo may be considered both a “Controller” and/or a “Processor” of personal data [Personal Information].  We are the Controller for all the personal data you provide to us as a Customer when you search our site or register for our Service. In our role as Controller we only use the personal data that we collect for legitimate business purposes that are consistent with this Privacy Policy and the Terms of Service. We are a Processor for any personal data you provide to us in relation to your consumers, callers or clients and the personal data we collect from those consumers, callers or clients at your direction as part of the Service. In our role as Processor, we follow instructions provided to us by you in relation to the personal data.

Location and Data Transfers

Soleo is based in the United States. Any personal data we collect, store or process will take place in the United States. For any transfers of personal data to the United States, we take reasonable precautions to ensure the protection of such personal data through use of administrative and physical security measures.  By using the Service, a data subject expressly consents to the collection, transfer and processing of his/her personal data outside of the European Economic Area. If you or your organization are required to enter into a Data Processing Agreement with your Processor pursuant to the GDPR, please contact legal@soleo.com.

Rights of Data Subjects

Pursuant to the GDPR, European Union Data Subjects have the following rights:

  • Access to his/her personal data
  • Rectification of personal data
  • Restrict or suspend processing of personal data
  • Complaint to the supervisory authority
  • Object to processing, including for direct marketing purposes
  • Receive personal data in a standard electronic format for data portability purposes

If Soleo is the Controller of the personal data, then the data subject may withdraw consent or exercise any other rights granted to him/her pursuant to the GDPR by contacting legal@soleo.com. Soleo will respond to any such requests within a reasonable timeframe.

If Soleo is the Processor of the personal data, then the data subject should contact you as the Controller to exercise any of their rights pursuant to the GDPR.

If you have any questions or concerns related to this Privacy Policy or how Soleo collects and maintains your Personal Information, please contact us at legal@soleo.com. We will get back to you about your request within a reasonable timeframe.

 

© Copyright 2019 Soleo Communications, Inc. All rights reserved.