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Privacy Policy

Privacy Policy

Last Updated October 1, 2020

Soleo is committed to handling any information it collects, that can be used to directly or indirectly identify you or any of your customers, including but not limited to, name, phone number, physical address, email address, and IP address (“Personal Information”), in a responsible manner through the use of administrative, technical, and physical safeguards.  The following policy (“Privacy Policy” or “Policy”) describes how Soleo collects, stores, shares, and uses any Personal Information you or your customers may provide to us while using any of our sites or Services as described herein. Our goal is to be transparent about how we handle Personal Information and respect your rights regarding access to and deletion of such Personal Information.

Soleo Communications, Inc. (“Soleo”, “We”, “Us”, or “Our”) provides several call management Services including our pay-per-call network known as CallThread. Our 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, store, share, and use the Personal Information you (“Customer”, “Publisher”, “You”, or “Your”), provide to us while accessing any of our sites:

In the event this Privacy Policy conflicts with a privacy policy provided for on any other Soleo owned and operated webpage, site, or platform, this Privacy Policy shall control. This Privacy Policy is expressly incorporated into the Terms of Service and Publisher Terms of Service, which apply to your access to and use of any of Soleo’s Services or platforms. BY USING ANY SITES OR SERVICES PROVIDED BY SOLEO, YOU CONSENT TO THIS PRIVACY POLICY AND TO OUR COLLECTION, 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 ANY OF OUR SITES OR SERVICES AND NAVIGATE AWAY FROM THIS SITE.

1. Description of services offered by Soleo. 

Soleo offers a variety of call management solutions including access to our pay-per-call platform known as CallThread. Features of our services include, but are not limited to: call automation using custom call routing and Interactive Voice Response (“IVR”) menu creation, voicemail, call recording, call transcription, call scoring, call tracking with number porting, number assignment, and call forwarding, real-time reporting dashboards, including third-party plug-ins and integrations, lead generation services including campaign management tools such as geolocation targeting, budget pacing, and a bid strength optimizer tool to determine competitive prices for leads by industry and location against current bid prices paid by competitors. Soleo also offers various telecom carrier-based solutions including, directory assistance, call handling for disconnected numbers, and IP relay service. These features and services are collectively referred to as the “Service(s)”.

2. When and how does Soleo collect Personal Information? 

Soleo collects Personal Information directly from you and from your customers, on your behalf, who interact with our Services or phone numbers assigned to you. Soleo may collect Personal Information when a call is placed to any of the phone numbers associated with our business or support lines, when you search through any of our sites, when you register for an account or use our Services, when you add or change your account information, including credit card or other payment information, when you or your customers interact with any of our Services by phone, online or via mobile application, or when you or your customers interact with any third-party sites or applications that are linked to our Services.

Soleo may collect specific Personal Information when a caller places a call to a phone number directed to any of our Service platforms. Such information may include the caller’s name, phone number, address, location, name and type of business the customer is calling, and other personally identifiable information. These calls may be monitored and/or recorded as discussed in this Privacy Policy.

Additionally, Soleo or you may create other information gathering tools to collect certain Personal Information from your customers when they interact with certain features of our Services. Soleo will collect and handle that information as set forth in this Privacy Policy. However, Soleo shall not be liable to any of your customers or other third parties 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 customers.  

On occasion we may also ask you to provide information based on your experience using our Services. 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.

3. Call Recording and Call Transcription. 

Soleo offers call recording and transcription features as part of its Services. Any caller placing a phone call to a phone number, assigned by, associated with, or directed to any of our Service platforms for call handling by Soleo should be aware that they could be disclosing Personal Information, including sensitive Personal Information, which may include, but is not limited to, financial account information and medical or health information, during the call. Calls may be monitored and/or recorded for quality assurance purposes and may also be transcribed at your direction.

We 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 our Service. 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. Soleo may make the call recordings and transcripts available to you through your account. Soleo shall not be liable to you or your customers as it relates to your collection or use of your Customer’s Personal Information, including sensitive Personal Information, provided on any call recordings or transcripts captured as part of our Services. Your own privacy policy shall govern your obligations and liabilities as it relates to your customers.

Callers are not obligated to disclose any Personal Information while using any of Soleo’s Services and should be aware they are solely responsible for any disclosures of Personal Information, including sensitive Personal Information, they may make during any calls handled by Soleo. You are responsible for communicating this information to your customers who may use our Services.

4. What Personal Information does Soleo collect? 

We may collect the following Personal Information from you or your customers, on your behalf, when interacting with our sites or Services:

  • your name or the name of your customers;
  • the name of your business;
  • your job title and employer;
  • your phone number or your customer’s phone number;
  • the phone number of your business;
  • your email address or your customer’s email address;
  • the email address of your business;
  • the hours of operation of your business;
  • geolocation information pertaining to your business or your customers;
  • credit card, debit card, bank account or other payment information that you provide to arrange for payment of our Services, directly or indirectly, through our sites or third-party payment processors;
  • other details about your business in connection with the creation of your account to help you better utilize our Services,
  • 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 to your account;
  • device-specific information from you or your customers (for example: tablet model, mobile phone model, operating system version, and mobile network information);
  • the ISP used by you or your customers;
  • the browser type and version used by you or your customers;
  • your IP address or the IP address of your customers;
  • what pages, reports, widgets, and other tools you used in relation to our Services;
  • 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 we send to your electronic devices or the electronic devices of your customers.

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 electronic device 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 our sites or Service, enhance your user experience, and help us improve our Services. Some Cookies are automatically deleted at the end of a web session; however, we 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 outs 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 Personal Information for the following purposes:

  • to communicate with you about the Services we provide;
  • to provide you with the Services you register for or sign an agreement for;
  • to customize aspects of our Service to fit your needs;
  • to maintain, improve, and provide basic functionality of our Services;
  • to resolve any support tickets or service requests;
  • to publicize campaigns on our call network;
  • to send you information on promotions or events;
  • to send you newsletters, blogs, white papers, case studies, 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.

Additionally, with your consent we may use information about you for a specific purpose not listed above, such as, in marketing materials including testimonials, articles, or other sales related materials use to promote our Services.

7. Will Soleo disclose Personal Information? 

Except as provided in this Privacy Policy, Soleo will only use the Personal Information it collects as it relates to the Services it provides to you. Soleo will not sell, rent, trade, or otherwise disclose or transfer any Personal Information to any third party without your 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 our sites and Services 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, Publisher Terms of Service, or any other agreement in place between you and Soleo;
  • to respond to access or deletion requests of Personal Information from you or your customers; and/or
  • to protect the rights, property, or safety of Soleo, its users or the general public.

8. How does Soleo protect Personal Information?

Soleo undertakes several precautionary measures to maintain the security of all sites and platforms related to our Services and the collection and storage of Personal Information. Personal Information is stored on secure servers at secure locations. Soleo protects Personal Information online by ensuring that our third-party data center service provider(s) use industry standard encryption methods to prevent unauthorized access to Personal Information stored on our servers and platforms as well as conducting pen testing to prevent attacks from hackers. Additionally, Soleo uses PCI-compliant payment processing vendors. Soleo protects Personal Information offline through the use of restricted access protocols that limit access to our facilities and systems that contain Personal Information to authorized personnel that require access to the Personal Information in order to fulfill their duties. We also have procedures in place to handle any suspected or actual data breaches in the rare and unlikely event that a breach occurs.

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 transmitted to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. We do take commercially reasonable efforts to protect Personal Information in our possession.

Soleo may store and process Personal Information in any state or country in which Soleo or its third-party vendors maintain 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 may 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 accessing any of our sites and using our Services you consent to the transfer of your Personal Information outside of your state and/or country.

9. What about links to third-party sites or applications?

Our Privacy Policy applies solely to information that is acquired by Soleo through its provision of Services or any associated sites or platforms. The Service may include links to third-party websites neither owned nor managed by us. Additionally, if you use any plug-ins or third-party integrations or applications associated with our Services, the service provider of such third-party site or application may obtain your Personal Information. Soleo does not and cannot control how third-party sites may obtain or use your Personal Information. Soleo is not associated with any third-party sites and 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.

10. Social media platforms and other public forums?

Soleo’s sites and platforms associated with our Services may 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.

11. Can Soleo modify this Privacy Policy?

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, by posting a notice on our sites, or by posting a notice or alert in your account. Any revised versions of this Privacy Policy shall be effective immediately upon posting. You agree that your continued use of our Services following such notification or posting shall constitute your acceptance of the revised Privacy Policy.

12. 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, Terms of Service, Publisher Terms of Service, or any other agreement that governs our business relationship with you; 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 such Personal Information in cases where the Personal Information (a) relates to Customers that are no longer using our Services, (b) relates to Customers that have not accessed our Services for a substantial period of time, or (c) where Soleo, in its sole discretion, believes the Personal Information is no longer current or accurate or needed for any legitimate business purposes.

Please note, if you cancel your Service, or if your account is terminated for any reason, we provide no guarantee that your account 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 account data and Personal Information have been deleted.

13. 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 comply with all applicable laws and industry best practices in relation to responding to requests submitted by you to update or delete Personal Information, unless it is required to be retained by law or for any lawful business purpose consistent with this Privacy Policy, Terms of Service, Publisher Terms of Service, or any other agreement that governs our business relationship with you. You may edit some of your own Personal Information online through your account settings. If you would like access to the Personal Information Soleo maintains about you or to have any Personal Information updated or deleted please contact your Soleo Account Manager, or if you don’t have a dedicated Account Manager please contact legal@soleo.com. Soleo will accommodate any such requests within a reasonable timeframe or within the timeframe established by any applicable laws or regulations and upon verification of your identity, unless the Personal Information is required to be retained by us pursuant to an applicable law or for a lawful business purpose.

Soleo does not target or direct its Services directly to consumers (e.g. your customers). The Services we provide are business to business solutions. Therefore, if a consumer seeks to access, or otherwise update or delete his/her Personal Information that Soleo may collect or maintain in relation to our provision of Services to you, then we will direct that consumer to contact you directly and refer to your privacy policy for such procedures. If a consumer does direct an inquiry related to their Personal Information to Soleo, we reserve the right to respond directly to the consumer in order to protect our interests.

14. Can I opt out from providing my Personal Information?

You must provide your Personal Information 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 Services. 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. Our 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 occasion to send you information related to any planned or unplanned Service outages. You agree that we may contact you with important updates about your account or Service. 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 purposes. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Such interest can be shown through opening emails from us or the date you last used any of your accounts to access our Services. If you wish to opt out of receiving such marketing related commutations simply click the ‘unsubscribe’ link in the promotional communication. 

15. California Residents – California Consumer Privacy Act (CCPA).

This section applies only to consumers that are Residents of California. Soleo’s Service and platforms are business to business solutions. 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 this Section shall govern with respect to the rights of California consumers regarding their Personal Information and Soleo’s responsibilities with regard to such Personal Information. Soleo does not sell Personal Information, but we may share Personal Information with third-party service providers who are contractually obligated to meet the same requirements as Soleo regarding the CCPA. For the purposes of this Section “Personal Information” shall have the meaning defined under the CCPA. As required by the CCPA, this Privacy Policy describes the categories of Personal Information collected, used, and disclosed by Soleo, the methods we use to collect Personal Information, and the commercial purposes for collection, processing, or disclosure of Personal Information.

California Consumer Rights

  • You have the right to access your Personal Information that we have collected, used, disclosed, or sold, including the right to receive, once per year, the following information:
    - Categories of Personal Information about you that we collected in the preceding 12 months and the source of such Personal Information;
    - Commercial purpose we collected, used, disclosed, or sold your Personal Information; and
    - Third parties to whom we have disclosed or sold your Personal Information to in the preceding 12 months.
  • You have the right to request that we delete any of your Personal Information in our possession.
  • You have the right to opt out from the collection of your Personal Information as well as any marketing communications that are not required as part of the provision of any Services to you.

How to Exercise Your Rights Under the CCPA

If you wish to make a request to access, delete, or to opt out related to your Personal Information you may do so by submitting a request to our online portal or by contacting us at legal@soleo.com. We will respond to requests in a timely manner and to the extent required to do so under the CCPA. You may also designate an authorized agent to exercise your rights on your behalf, but we may request that your authorized agent have written notarized proof of their permission to act on your behalf. We will also verify the authorized agent’s identity.

There may be cases where we decline a request you make under the CCPA as may be permitted by law. Prior to responding to any requests under the CCPA we will verify your identity to protect your privacy and prevent anyone from improperly obtaining your Personal Information. If you have a password protected account, we will verify your identity using that account. If not, Soleo will ask you to provide one or more pieces of information such as proof of your name, address, or phone number.

Pursuant to the CCPA, we do not collect, use, or sell Personal Information about minors between the ages of 13 and 16 without an opt in authorization. Please reference Section 17 of this Privacy Policy for more information related age restrictions.

16. EEA Residents – General Data Protection Regulation (GDPR).

Lawful Basis for Controller and Processor Activities

If you are an individual in the European Economic Area (EEA), we may collect and process Personal Information about you or any Data Subject, as defined under the GDPR, where we have legal basis for doing so. Personal Information under this Section shall have the meaning assigned to Personal Data under the GDPR.

We may collect your Personal Information for the following reasons:

  • We need it to provide Services to you, including providing customer support, personalized features, or to protect the security of our platforms; or
  • You give us consent to do so for a specific purpose such as using our sites or Services.

By using any of our sites or Services you consent to our collection, use, disclosure or transfer of your Personal Information. If you have consented, you have the right to change your mind at any time, but this will not affect any processing that has already taken place and you may no longer be able to access our sites or Services after you withdraw consent.

Role as Controller or Processor

Soleo may be considered a Controller and/or a Processor of Personal Information as defined in the GDPR. We are the Controller for all the Personal Information you provide to us when you search our site or use our Services. In our role as Controller we only use the Personal Information we collect for legitimate business purposes that are consistent with this Privacy Policy, Terms of Service, Publisher Terms of Service, or any other agreement governing our business relationship with you. We are a Processor of any Personal Information you provide to us in relation to your customers and any Personal Information we collect from your customers during our handling of any calls directed to any of our Service platforms. In our role as Processor, we follow instructions provided to us by you in relation to the Personal Information.

Location and Data Transfers

Soleo is based and operated in the United States. We may transfer any of your Personal Information we collect, use, store, or process to the United States or to any other country where a Soleo affiliate or third-party vendor is located for the purpose of processing or storage. Any such affiliate or third-party vendor shall be contractually obligated to meet the requirements of a Processor under the GDPR. 

For any transfers of Personal Information to the United States, we take industry standard precautions to ensure the protection of such Personal Information through use of administrative and physical security measures. If you or your organization are required to enter into a Data Processing Agreement including Standard Contractual Clauses with your Processor pursuant to the GDPR, please contact legal@soleo.com.

By using our sites and Services, you, and any Data Subject under the GDPR expressly consent to the collection, use, transfer, and processing of Personal Information outside of the EEA.

Rights of Data Subjects

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

  • Access to his/her Personal Information
  • Rectification of Personal Information meaning a Data Subject may correct or supplement Personal Information
  • Restrict or suspend processing of his/her Personal Information
  • File a complaint to the supervisory authority in his/her EU state
  • Object to processing of his/her Personal Information, including for direct marketing purposes
  • Receive his/her Personal Information in a standard electronic format for data portability purposes
  • Erasure or deletion of his/her Personal Information
  • Withdraw Consent previously granted in relation to collection of Personal Information

Exercising Your Rights

If Soleo is the Controller of the Personal Information, 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 and to the extent required to by the GDPR.

If Soleo is the Processor of the Personal Information, then the Data Subject should contact you as the Controller to exercise any of their rights pursuant to the GDPR. Your privacy policy and data processing procedures shall govern in such case.

17. Age Restrictions

You must be at least 18 years old to access our sites and register for our Services. Our sites and Services are compliant with the Children’s Online Privacy Protection Act and are not targeted, designed, or intended to collect Personal Information from children under the age of 13. Soleo does not knowingly collect Personal Information from children under the age of 13. If you are under 13, you are strictly prohibited from using our sites, registering for our Services, making any purchases through our sites, using any of the interactive or public comment features on our sites, or providing 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.

18. Contacting Soleo

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

If you are unable to access this Privacy Policy due to a mental or physical disability or impairment, please contact us at legal@soleo.com and we will arrange to supply you with any information you need in an alternative medium that allows you access to it.

© Copyright 2020 Soleo Communications, Inc. All rights reserved.