Last Updated: 01 January 2025

1. Introduction

Purpose of this Notice

Solvation LLC (“Solvation” or “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Notice (our “Privacy Notice” or “Notice”) describes the types of information we may collect from you or that you may provide when you visit our website at www.solvationservices.com (the “Website”) and/or communicate with us (whether electronically, in-person at events or tradeshows, or otherwise), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to communicate with us or use our Website. By communicating with us or accessing or using our Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued communications with us and/or use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

2. Scope and Applicability of this Notice to You

We provide privacy consulting, implementation, and managed services to companies (our clients) for building, expanding or otherwise enhancing their internal privacy and information governance programs and related initiatives, as well as streamlining their compliance efforts with data protection laws around the world. As part of our services, our clients may share limited identifying information about individuals with us to perform support services including, but not limited to, managing individuals’ privacy rights requests received by our clients. To facilitate these services, we primarily use our client’s infrastructure and do not download the individually identifiable information that is made available to us in the course of providing these services onto our own systems. When we are collecting or otherwise processing information about you on behalf of our clients, we will only collect, use, and otherwise process your information as directed by our clients, as set forth in our contractual agreements with such clients or as otherwise permitted by applicable law. Accordingly, this Privacy Notice does not apply to the extent we process your information, including any Personal Data (as defined below), in the role of a processor or service provider on behalf of our clients.

Thus, if you contact us or otherwise transmit information to us (or our client) in connection with exercising your privacy rights request, or if we download files with your information for import/export operations into our client systems during implementations or managed services for our clients, this Privacy Notice does not apply to any information you provide in those settings, as we merely collect this information as part of the services we perform on behalf of our clients. For detailed privacy information related to our collection and use of your information on behalf of the Solvation client who uses our services, or if you need to access or delete any Personal Data we may have collected about you as permitted by applicable law or the agreement between us and our client, please reach out to the company directly. We are not responsible for the data security practices of our clients, which may differ from those set forth in this Privacy Notice.

If you are a Solvation employee, independent contractor, or job applicant, your information collected in those contexts is subject to a separate privacy notice that we provide to you where and when appropriate. If Solvation is not acting as a processor or service provider, and your Personal Data is not otherwise excluded as set forth above, the following information applies to how we, collect, use, and disclose your Personal Data collected via our Website and through your communications with us (whether electronically, in-person at events and tradeshows, or otherwise).

3. Information We Collect About You and How We Collect It

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. However, Personal Data does not include any deidentified or aggregated information.

Generally

We collect Personal Data from various sources, including:

• directly from you when you provide it to us;
• automatically as you access, navigate through, or otherwise use the Website; and
• from third parties.

Information You Provide to Us

We collect the following types of Personal Data directly from you when you access or use our Website, provide it to us in-person (such as a conference or tradeshow) or share in any of your communications with us: real name, email address, and telephone number. In addition, we may also collect certain types of non-Personal Data that you may:

• choose to submit on our Website, such as when filling out a form, making a general inquiry, or requesting information about our products and services (e.g., job title and the name of the company with whom you are affiliated);
• provide in-person, such as during our interactions with you at a conference or trade show (e.g., business contact information – business address, email address, and telephone number);
• and share when you communicate with us, such as by phone or via email (e.g., records and copies of your correspondence).

Information We Collect Through Automatic Data Collection Technologies

We may also use automatic data collection technologies to collect the following information about your interaction with our Website. This information primarily consists of non-Personal Data but may include certain Personal Data or information we may maintain or associate with Personal Data we collect in other ways.

• Details of your visits to our Website, including location data (which may be used to locate the city and state that you are in but cannot be used to precisely locate you), referring/exit pages, date and time of your visit, error information, and other communication data and the resources that you access, use, or otherwise interact with on the Website.
• Information about your computer and internet connection, such as your IP address.
• Information collected through cookies (or browser cookies) running on our Website. Cookies are small data files placed on your computer that allow us to collect certain information whenever you visit or interact with our Website. Some of these cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies). For example, we use Google Analytics, a web analytics service provided by Google, Inc., to collect certain information relating to your use of our Website. Google Analytics uses cookies to help us analyze how users use our Website. For more information regarding Google Analytics (including how Google uses data when you visit our Website), please visit Google’s website and the pages that describe Google Analytics, such as https://policies.google.com/technologies/partner-sites.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our Website are served by third parties, including advertisers, ad networks and servers, content providers, analytics providers, social media companies, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these 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 responsible provider directly.

Information We Collect From Third Parties

We may also collect basic profile information, including contact information, from third parties, such as LinkedIn. When we associate this information with other Personal Data about you, we consider this information to be Personal Data.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data, for the following purposes:

• Fulfilling or meeting the reason that you provided the Personal Data.
• Providing, supporting, improving, debugging, and developing our Website, products, and services.
• Sending you newsletters and other similar communications with information that you request from us or that may be of interest to you, including marketing materials and offers relating to our products and services (with your consent, where required by law).
• Monitoring the performance of our Website, including metrics such as total number of visitors, and traffic.
• Providing you with support and responding to your inquiries (including investigating and addressing concerns and monitoring/improving responses).
• Maintaining the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• Notifying you about changes to our Website or any products or services we offer or provide through them.
• Understanding how you use our Website and identify any issues in how the Website is used and how we can improve your experience with our Website.
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Solvation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Solvation about our Website’s users and other individuals is among the assets transferred.
• Carrying out our obligations/enforcing our rights arising from any contracts entered into between you and us.
• Exercising or defending legal claims, and to respond to legally binding requests from law enforcement, regulatory authorities, or other third parties.
• Complying with our legal, regulatory, and contractual obligations.
• For any other purpose disclosed by us when you provide the information.
• With your consent (where required by law).
• As otherwise permitted or required by law.

5. How We May Disclose Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice, including any applicable jurisdiction-specific addendum appended to this Privacy Notice (if any). However, we may disclose aggregated information about you, and information that does not identify you, without restriction. In addition, we may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to third-party cookie providers for the purpose of providing analytics;
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Solvation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Solvation about its Website’s users and other individuals is among the assets transferred;
• to third parties to market their products or services to you if you have consented to these disclosures;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information;
• and with your consent (if required by law) or as otherwise permitted by applicable law.

We may also disclose your Personal Data to:

• comply with: (i) federal, state, or local laws, or to comply with a court order or subpoena to provide information; (ii) civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; and/or (iii) certain government agency requests for emergency access to your Personal Data if you are at risk or danger of death or serious physical injury;
• cooperate with law enforcement agencies concerning conduct or activities that we (or one of our service providers’) believe may violate federal, state, or local law;
• engage in any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, dissolution, or restructuring of (or similar transaction involving) all or part of our business;
• and/or exercise or defend legal claims, and to enforce or apply our Terms of Use and other agreements;
• and protect the rights, property, or safety of Solvation, its clients, or others.

6. Your Choices About How We Use and Disclose Your Information

We generally do not control the use of your information, which is received by those third parties described above in How We May Disclose Your Information. When possible, however, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other clients for their own purposes. In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Cookies. You can set your browser or device to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly. You may also disable our use of any non-essential cookies (e.g., analytics cookies) through our cookie consent manager, which you may access by clicking the cookie settings link in our cookie consent banner on our Website. You can find more information about cookies at http://www.allaboutcookies.org.
  As noted above, 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. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
• Direct Marketing/Promotional Offers from Solvation. We may send promotional or marketing-related emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time by clicking the “unsubscribe” link at the bottom of the email. If you opt-out of receiving these types of emails from us, please note that you may continue to receive transactional communications from us.

7. Other Rights and Disclosures

In addition to the choices made available to you with regard to the Personal Data that you provide to us, you may also send us an email at privacy@solvation.llc to request access to, correct or delete any Personal Data that we have collected about you. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

8. Do Not Track & Global Privacy Control Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Our Website incorporates technology designed to honor such signals and some similar mechanisms that may be sent by your browser or device and we may limit the Personal Data or other information we collect and/or how we use your Personal Data or other information based upon whether such a signal is transmitted by your browser or device and received by us.

In addition, some web browsers and browser extensions also permit you to broadcast the Global Privacy Control signal (“GPC Signal”), as specified at https://www.globalprivacycontrol.org. Our Website is designed to honor the GPC Signal and/or we may limit the Personal Data or other information we collect and how we use your Personal Data or other information based upon whether such a signal is transmitted by your browser or device and received by us.

9. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. To the extent we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.

10. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any Personal Data to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use the Website or provide any information on our Website or through any of its features. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 18, please contact us at privacy@solvation.llc.

11. Third-Party Sites

Our Website may contain links to third-party websites or services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or services. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we suggest you review.

12. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page and we may post a notice that the Privacy Notice has been updated on the homepage of our Website. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address we have on file, through a notice on the homepage of our Website, or by using a similar method. The date this Privacy Notice was last updated is identified at the top of the first page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at privacy@solvation.llc or through the “Contact Us” page on our Website.