Solesis, LLC Privacy Policy

Solesis, LLC and its subsidiaries, affiliates, and related companies and brands  (“Solesis,” “us”, “we”, or “our”) operate the websites https://www.solesis.com/, https://chartermedical.com/, https://www.polyzen.com/, https://sanavitamedical.com/, and https://secant.com/ (collectively, the “Services”).

This Privacy Policy describes our policies regarding the collection, use and disclosure of Personal Data when you use our Services and the choices you have associated with that data. This Privacy Policy applies to Personal Data that we collect:

• Through our Services.
• In email, text, chat and other electronic messages between you and Solesis.
• In person, over the phone, in writing or through the mail.

It does not apply to information collected by:

• Any third party to whom you provide your Personal Data or other information directly.
• Any third party, including through any application or content that may link to or be accessible from or through the Services.

Please read this Privacy Policy carefully to understand our policies regarding the collection, treatment and use of your Personal Data. If you do not agree with our policies and practices, you should not use our Services or provide your Personal Data to us. By using the Services, you agree to the collection and use of Personal Data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use https://solesis.com/terms-of-use/.

We may modify this Privacy Policy from time to time. The Effective Date of this Privacy Policy, and any changes or modifications it contains, is posted at the top of this page. Your continued use of the Services after we make changes is deemed to be acceptance of those changes. We therefore recommend that you periodically review this page for updates.

Definitions

• Services

The Services are the websites, https://www.solesis.com/, https://chartermedical.com/, https://www.polyzen.com/, https://sanavitamedical.com/, and https://secant.com/, operated by Solesis.

• Personal Data

Personal Data means data or information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, natural person, or household.

• Usage Data

Usage Data is data collected automatically, which is either generated by and through the use of the Services or from the Services’ infrastructure itself (for example, the duration of a page visit).

• Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for and the manner in which any Personal Data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

• Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

• Data Subject (or User)

Data Subject is any consumer or natural person who is using our Services and is the subject of Personal Data.

Information Collection and How It Is Collected

We collect several different types of information when you visit the Services, including:

• Personal Data. While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you or your household. Personal Data includes name, postal address, email address, telephone number, job title, company name, and/or any other identifier by which you may be contacted online or offline.
• Usage Data. We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as your device’s IP address, browser type and version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
• Payment information, financial information, and details on your transactions and purchases.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, device information, and information collected through cookies, web beacons, pixels and other tracking technologies.
• From our Service Providers, business partners, affiliates and vendors.

Information You Provide to Us

The information we collect on or through our Services may include:

• Personal Data and other information that you provide by filling in forms on our Services. This includes information provided when you fill out a contact form. We may also ask you for information, including Personal Data, when you enter a contest or promotion sponsored by us, or when you report a problem with our Services.
• Records and copies of your correspondence (including Personal Data like contact information, such as phone numbers and email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes (which may include Personal Data, if you choose to provide it).

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your device, equipment, browsing actions and patterns, including:

• Details of your visits to our Services, including traffic data, logs, and other communication data and the resources that you access and use on the Services.
• Information about your device and internet connection, including your IP address, operating system and browser type.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized experience, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Services.

Tracking & Cookies Data

The technologies we use for this automatic data collection may include:

• Google Analytics. We use Google Analytics to optimize our Services based on the traffic we receive and assist with marketing. To learn more about Google Analytics, including options for opting out and/or managing the ads you may see online, please visit: https://policies.google.com/technologies/partner-sites.
• Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics about our Services (for example, recording the popularity of certain website content and verifying system and server integrity).
• Session replay tools. We may use session replay tools to better understand our users’ needs and to optimize the Services. Session replay helps us better understand our users’ experience, including how much time they spend on which pages, which links they choose to click, what users do and do not like, etc. Some session replay tools may allow us to visually represent where users click, move and scroll on our Services.  This type of technology enables us to build and maintain our Services with user feedback. Session replay tools may use cookies and other technologies to collect data on our users’ behavior and their devices.
• Cookies (or browser cookies). Cookies are files with a small amount of data which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. Cookies allow the Services to recognize your device, store your preferences, and enhance your user experience. Cookies can be session-based (which are deleted when you close your browser) or persistent (which are stored on your device until they expire, or you delete them).

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services or they may not function correctly.

Examples of Cookies We Use

We may use multiple types of cookies, including:

• Strictly Necessary Cookies. These cookies (e.g., session cookies and security cookies) are essential to provide core functionalities of our Services, such as maintaining sessions and verifying you are a human user. Without these cookies, our Services cannot function properly.
• Functional Cookies.
  • Preference and Functionality Cookies. These cookies allow us to personalize your experience by remembering your preferences, like language selection or display settings.
  • Performance and Analytics Cookies. These cookies collect valuable insights on how users interact with our Services. By tracking performance metrics like loading times, popular features and navigation patterns, we can make informed decisions to improve functionality and create a seamless user experience.
• Marketing Cookies.
  • Marketing and Advertising. We use marketing and advertising cookies to help us deliver content, advertising and messaging designed to appeal to your interests. By capturing your interactions with us and our activities, we can tailor our actions to your preferences, interests and previous behavior.
  • Third-Party Cookies. Third-party tools, software and platforms we use to support sales, marketing and customer success efforts may use cookies to help deliver messages, content and ads that are relevant, timely and engaging. By tracking your interactions, we can tailor our activities to your preferences, interests and previous behavior as well as improve their performance and effectiveness. We recommend you separately review the privacy and cookie policies of these third-party providers.

Cookie Management

You can manage and disable cookies in several ways:

• Browser Settings. Most browsers allow you to modify cookie settings under a “Preferences” or “Options” menu.  You can delete or block cookies, but please note that disabling certain cookies may impact your experience with our Services.
• Cookie Consent Banner. When you visit our Services for the first time, a cookie banner will appear, allowing you to accept or reject all cookies that are not strictly necessary.
• Third-Party Opt Out. We do not control third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Impact of Disabling Cookies

• While you can disable cookies, please note that certain core features and security functions may be limited, especially features essential for logging into and using our Services.

Categories of Personal Data Collected in the Past 12 Months

The tables below show the categories of Personal Data and Sensitive Personal Data that we have collected in the past 12 months. Please note that while examples of every category are shown, not every example has necessarily been collected.

How We Use Your Personal Data

We may use the information that we collect about you, or that you provide to us, including Personal Data:

• To provide and maintain our Services.
• To notify you about changes to our Services.
• To allow you to participate in interactive features of our Services when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve our Services.
• To monitor the usage of our Services.
• To detect, prevent and address technical issues.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the Personal Data described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Solesis may process your Personal Data because:

• We need to perform a contract with you.
• You have given us permission to do so.
• The processing is in our legitimate interests and it is not overridden by your rights.
• To comply with the law.

Retention of Personal Data

Unless you specifically ask us to delete your Personal Data, we will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. Solesis will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or improve the functionality of our Services, or we are legally obligated to retain this data for longer periods. Additionally, we will retain Personal Data related to marketing activities for as long as you accept marketing communications from us.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers and servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy through your use of the Services and your choice to submit your Personal Data to us represents your agreement to the transfer of your Personal Data to the United States.

Solesis will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. Your Personal Data will only be transferred to an organization or a country where there are adequate controls in place to reasonably ensure the security of your Personal Data.

Disclosure of Data

We may disclose Personal Data we collect, or you provide, as described in the Privacy Policy:

• To subsidiaries and affiliates.
• To Service Providers and other third parties we use to support our business operations.
• To a buyer or other successor in the event of a merger, divestiture, restructuring reorganization, dissolution, or other sale or transfer of some of all of Solesis, LLC’s assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which Personal Data is held by Solesis, LLC is among the assets transferred.
• To fulfill the purpose for which you provided the information.
• With your consent.

Disclosure for Law Enforcement

Under certain circumstances, Solesis may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements

Solesis may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation.
• Protect and defend the rights or property of Solesis.
• Prevent or investigate possible wrongdoing in connection with the Services.
• Protect the personal safety of users of the Services or the public.
• Protect against legal liability.
• Enforce or apply our Terms of Use https://solesis.com/terms-of-use/.

Choices About How We Use and Disclose Your Personal Data

As described above, we may use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We have created mechanisms to provide you with the following control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of these Services may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted advertisements from members of The Network Advertising Initiative (“NAI”), visit the NAI’s website at NAI: How to Opt Out.

If you do not wish to receive promotional or marketing emails or newsletters from us, you can opt out by clicking the Unsubscribe link on the marketing email you received at any time or by sending us an email at privacy@solesis.com. Please note that we will still send you transactional emails and informational emails about your account.

Security of Data

The security of your Personal Data is important to us, and we will use reasonable security measures to prevent the loss, unauthorized access to, use, alteration, or destruction of your Personal Data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal Data, we have put in place appropriate physical, electronic, and organizational measures to safeguard and secure the Personal Data we collect. We monitor our Services for potential vulnerabilities and attacks.

However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee the security of your Personal Data transmitted to, through, or in connection with the Services. In particular, email, texts and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of Personal Data is at your own risk. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

The safety and security of your Personal Data also depend on you. You are responsible for taking steps to protect your Personal Data against unauthorized use, disclosure, and access.

“Do Not Track” Signals

We do not respond to Do Not Track (“DNT”) signals at this time. We will respond to such signals in the future, if and when we are required to do so.

Your Privacy Rights under European Law

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Solesis aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at privacy@solesis.com or submit a webform at https://www.solesis.com/contact-us/.

Residents of the EEA have the following data protection rights available to them:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your Personal Data rectified if that Personal Data is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
• The right to data portability. You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Solesis relied on your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Privacy Rights Under State Privacy Laws

State consumer privacy laws, such as the California Privacy Laws, provide their residents with additional rights regarding our use of their Personal Data. These rights are described below.

The Right to Know and to Confirm, and the Right to Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months (the “right to know” and the “right to confirm”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of Personal Data that we collected about you.
• The categories of sources for the Personal Data we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Data.
• The categories of third parties with whom we share that Personal Data.
• If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
  • Sales, identifying the Personal Data categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.
• The specific pieces of Personal Data we collected about you (also called a “data portability” request).
• If you submit a data portability request, we will provide you with a copy of your Personal Data in a common and portable format that you may transfer to another organization of your choosing.

The Right to Delete

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

• Complete the transaction for which we collected the Personal Data, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another individual to exercise their free speech rights, or exercise another right provided for by law.
• Comply with specific laws, such as the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Data not subject to one of these exceptions from our records and will direct our Service Providers to take similar action.

The Right to Correct Inaccurate Personal Data

You have the right to correct any inaccurate Personal Data about you that we have in our possession (the “right to correct”).  Once we receive your request and confirm your identity, we will disclose to you the specific pieces of Person Data that we have collected about you.  You will then have the opportunity to direct us to correct the pieces of information which you believe are inaccurate.

We may deny your request to correct if we believe the updated Personal Data is incorrect or is being used for any fraudulent or deceptive purpose.

The Right to Restrict Sensitive Personal Data Processing

You have the right to restrict our processing of your Sensitive Personal Data (the “right to restrict”).  Once we receive your request and verify your identity, we will cease the processing of your Sensitive Personal Data for the purpose of inferring characteristics about you.  Please note that we may continue to process your Sensitive Personal Data for other purposes consistent with this Privacy Policy.

The Right to Opt Out of the Processing and Sale of Personal Data

You have the right to direct us to not process your Personal Data for targeted advertising and to not sell your Personal Data at any time (the "right to opt-out"). Once we receive your request, we will no longer use or process your Personal Data for the purpose of providing targeted advertising to you based on your activity and interests.  We will also no longer sell (as that term is defined by relevant and applicable state law) your Personal Data to third parties for targeted advertising purposes.

The Right to Opt Out of the Sharing of Personal Data for Cross-Contextual Behavioral Advertising

You have the right to opt out of the sharing of your Personal Data with third parties for cross-contextual behavioral advertising.  Once we receive your request, we will no longer use or process your Personal Data for the purpose of advertising to you based on your individual activity.

The Right to Opt Out of Profiling

You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects to you.  Once we receive your request, we will no longer use or process your Personal Data for making decisions that produce a legal or similarly significant effect to you.

The Right to Be Free from Discrimination

We will not discriminate against you for exercising any of your rights under applicable state privacy law.  Unless permitted by state law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by state privacy law that can result in different prices, rates, or quality levels. This may include loyalty and rewards programs. Any legally permitted financial incentive we offer will reasonably relate to your Personal Data’s value and will contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Exercising Your Rights

To exercise your rights described in this Privacy Policy, you may submit a request to us by:

• Sending us a message online at: https://www.solesis.com/contact-us/
• Emailing us at: privacy@solesis.com
• Calling us at: 1-877-774-2835
• Mailing us at:

Solesis, LLC ATTN: Legal Department

551 East Church Avenue

Telford, Pennsylvania 18969

Only you or someone legally authorized to act on your behalf may make a request related to your Personal Data.  You may also make a request on behalf of your child.  You may only submit a request twice within a 12-month period.

We may not require you to provide additional Personal Data to verify your identity for opt-out requests.  However, to process other requests, we may require you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative, which may include:
  • Provide at least three (3) pieces of information that match the Personal Data we have about you.
  • Provide a signed declaration, under penalty of perjury, that you are the individual about whom you have submitted the request, or that you are legally authorized to submit the request on the individual’s behalf.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm that the Personal Data relates to you.

You do not need to create an account with us to submit a request.  We will only use the Personal Data provided in the request to verify the requestor’s identity or authority to make it.

You may appeal a decision concerning your privacy rights by emailing us at privacy@solesis.com or by writing us at:

Solesis, LLC ATTN: Legal Department

551 East Church Avenue

Telford, Pennsylvania 18969.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email privacy@solesis.com or call 1-877-774-2835.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we may deliver our written response to that account. Alternatively, or if you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click a third party’s link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

Children’s Privacy

Our Services are not intended for individuals under the age of 18.

No one under the age of 18 may provide any Personal Data to or on the Services. We do not knowingly collect Personal Data from anyone under the age of 18. If you are under 18, do not use or provide any information on these Services or through any of its features, or provide any information about yourself, including your name, address, telephone number, email address, or other Personal Data. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at privacy@solesis.com. If we become aware that we have collected Personal Data from a child under 18, we will delete that information.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services when changes become effective and we will update the “Effective Date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By filling out a webform online at: https://www.solesis.com/contact-us/
• By email at: privacy@solesis.com
• By writing to us at: 551 East Church Avenue Telford, Pennsylvania 18969
• By phone at: 1-877-774-2835