Privacy Policy

Last Updated March 5, 2026

This Privacy Policy (“Policy”) for HSB Solomon Associates LLC (Solomon) and/or its affiliates, and subsidiaries (collectively or individually, as applicable, referred to as “Solomon,” “Company” “us,” “we,” or “our”) which provide services to you describes how and why we might access, collect, store, use, share and transfer (“Process”) your information, including Personal Information as defined in this Policy, and how you can exercise your privacy rights. This Policy applies to interactions we have with you including through our website www.SolomonInsight.com and our other sites and online portals (the “Sites”), our applications, products and services, events, and when we otherwise display or link to this Policy (collectively, including “Sites”, the “Services”). Depending upon your relationship with us, you may receive other privacy notices from us providing additional details about our privacy practices. Please note that privacy rights and obligations may differ in certain locations based on applicable local data protection laws. We have included supplemental information for certain jurisdictions in this Policy.

If you enter into a separate agreement with us which describes Processing information about you that is different than that which is described in this Policy, the terms of that agreement will apply. Otherwise, your use of the Services is subject to this Policy and Solomon’s, including applicable terms of limitations on liability and the resolution of disputes.

If you are a California resident, please see the Additional Notice to California Residents section below for more information.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, please contact us at CorporateComm@SolomonInsight.com.

PERSONAL INFORMATION WE COLLECT

We collect and use information that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”) to fulfill our intended business purposes. Personal Information does not include publicly available information, such as information lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience, or deidentified, anonymized or aggregated information. To the extent we maintain, and use deidentified, anonymized or aggregated information, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification/ anonymization processes satisfy our legal obligations.

As described below, we collect Personal Information directly from you, automatically through your use of the Services, and from third-party sources. To the extent permitted by applicable law, we may combine the information we collect from publicly available or third-party sources. The Personal Information we collect varies based on what products or Services you have with us.

Personal Information We Collect Directly From You

You can visit our Sites and use certain features without creating an account. However, some features require you to provide us with certain Personal Information. While the Personal Information we collect varies depending upon your use of the Services and our interactions with you, we may collect the following Personal Information directly from you:

Identifiers and Contact Information. We collect personal identifiers and contact information such as your name, address, email address, phone number, contact preferences, job titles, contact or authentication data and other similar identifiers you choose to provide.
Registration and Profile Information. When you register for an account with us through our Site and on our digital portals, we collect information such as email, username, password, and any other information used in connection with accessing your account.
Message Contents. We may collect your messages, email contents, or any other information you so choose to provide when interacting with our team. We also maintain records of communications and information you post in blogs, forums, and in other areas of the Services.
Audio or Similar Information. If you speak with our team by phone, we may collect a recording for quality assurance and training purposes.
Preferences. We may also collect information about the types of Services you use, your communications preferences, wish lists and other preferences you may select in your account or profile.
Other Information. When you or leave us reviews, complete our online forms, surveys, or questionnaires, we may collect information such as user satisfaction, feedback, or other information related to your use of our Services. We also collect any other information you choose to provide.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Personal Information We Collect Automatically

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your name or contact information but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is collected and used to maintain the security and operation of our Services, for our internal analytics and reporting purposes, and to help us tailor content or offers for you and serve our targeted, interest-based advertising. These technologies may allow certain third parties to collect information about you over time and across different websites, such as information about you clicking on advertisements or installing our Services. Where permitted by applicable law, we will deploy first and third party performance, analytics and marketing cookies automatically when you visit our websites. Where required by applicable law, we will obtain your consent before we place any cookies on your device that are not strictly necessary for the functioning of our Sites. To learn more, including about how to consent to or opt-out and withdraw your consent to Cookies, please see our Cookie Notice.

As described below in the “Cookies and Other Tracking Mechanisms” section, when you visit our Sites, we also collect information through cookies, pixel tags tracking beacons and other similar technologies to automatically collect certain Personal Information.

The information we collect includes:

Device Identifiers. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Network Activity. We also collect information related to area(s) of the Services visited, how you interact with the Services and advertisements; date and time of access; host or Internet service provider (ISP) information; links and items clicked and other activity information, referring URL, browsing history, and other similar information. We may use analytics providers and technologies, including cookies and similar tools, to collect this information.
Geolocation. We also may collect geolocation information, such as physical location. Additionally, depending on your device settings, if you visit our Sites, we may collect geolocation information from your IP address which links to the region you live in. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location based on your IP address. You can opt out of allowing us to collect this information either by refusing access to the information or disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Personal Information We Collect from Other Sources

We may collect information about you through our affiliates, business partners, authorized representatives, advertising networks, data analytics providers, social networks, Internet service providers, operating systems and platforms, government entities, public databases, data brokers, vendors and service providers who provide services on our behalf, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

If you interact with us on a third-party’s social media platform using your social media account (e.g., LinkedIn or X), we receive personal information about you from such platforms such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings. Please note that a social media platform’s use of your information is governed by the platform’s Privacy Notice and is not governed by this Privacy Notice. We are not responsible for the personal information or any other information you choose to submit on third party platforms or other forums that are not controlled by us.

BUSINESS AND COMMERCIAL PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED AND USED

We may use the Personal Information we collect through the Services for the following business purposes:

Operate Our Business. We use the Personal Information we collect to allow you to create and maintain your account and otherwise run our day-to-day operations, and to otherwise enable you to use our Services.
Provide You Products and Services. We use the Personal Information we collect to provide you with, renew or modify products and services that you requested.
Communicate With You. We use the Personal Information we collect to communicate with you about your use of our Services, to respond to your inquiries, to provide you with the information and documents you request, changes to our terms and policies, and for other customer service purposes.
Evaluate and Improve Our Products and Services. We use the Personal Information we collect to evaluate, analyze, improve, and develop our products and the Services. We also use this information to tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using our Services.
Analytics to Support Our Business. We may also use this information to conduct research studies to maintain and develop our products and Services, and to create new offerings or features. We also use this information to administer surveys and questionnaires, such as for market research or member satisfaction purposes.
Marketing and Advertising. We may use your Personal Information for marketing and promotional purposes, including to send you promotional communications about products, services, features, and options we believe may interest you. We may send communications via e-mail, regular mail or may send push notifications via a mobile device. We may also use your Personal Information to serve you advertisements or customized content online. You can opt out of receiving email marketing communications from us by using the “unsubscribe” link in any marketing email we send you. If you opt out of receiving marketing messages, we may still send you non-marketing communications regarding the Services we provide to you.
Fraud and Security Purposes. We use the Personal Information we collect to mitigate fraud and protect Solomon and others. We also use this information to prevent and detect fraudulent, malicious, deceptive, infringements of our policies and contracts, to investigate privacy security or employment-related incidents, and other potential misuse of or illegal activity relating to our products, assets, and Services.
Legal Requirements. We use the Personal Information we collect to investigate, enforce, and apply this Policy and our Terms of Use , and to otherwise protect our own rights and interests, such as to resolve any disputes or to respond to requests from law enforcement, court orders, regulators, subpoenas, search warrants, other legal processes, or to perform other reporting obligations, as required by applicable law and to otherwise comply with applicable law.
Business Transfers. We may also use the Personal Information we collect and receive to consider and implement mergers, acquisitions, reorganizations, refinancing, and other business transactions, and for the administration of our general business, accounting, recordkeeping, and other legal functions.
Employment-Related Purposes. We may use your Personal Information for purposes including but not limited to recruiting, hiring, onboarding, performance reviews and staffing decisions; human resource management services; administration of employee benefits, compensation and expenses; maintenance of contact information; conducting healthcare-related services; and to provide alerts and notices.
Other Operational and Business Purposes. We may use your Personal Information for other operational purposes, for business purposes including to refer you to our business partners, and to comply with contracts related to products or Services that we provide to you. We also may anonymize, combine or aggregate any of the information we collect through the Services or elsewhere for any of these purposes or for analyzing usage statistics and trends.
As Described to You When We Collect Your Personal Information and as Otherwise Permitted under Applicable Law.

HOW WE MAY SHARE PERSONAL INFORMATION

When permitted by applicable law, including in cases that require your consent, we may disclose your Personal Information to our affiliates, business partners, vendors and services providers, and others (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information.

The categories of third parties we may share personal information with are as follows:

Affiliates and Subsidiaries. We may disclose the Personal Information we collect from you to our parent, affiliates, or subsidiaries.
Business Partners. Solomon also partners with other businesses to offer products and Services, and we may disclose your Personal Information to those organizations. If required by law, we will obtain consent prior to disclosing Personal Information.
Your employer. We may provide Personal Information to your employer for purposes such as to fulfill and enforce our contract with them, to inform them of potential group training needs, to inform them of use of our Services and for pricing purposes.
Vendors and Service Providers. We may disclose the information we collect to vendors, service providers, and contractors or agents who perform functions on our behalf, including deploying and analyzing surveys and advertising content, complete transactions and process payments. We may also disclose this information to vendors and service providers who provide website hosting, ad networks, sales and marketing tools, social networks, performance monitoring tools, retargeting platforms, communication and collaboration tools, user account registration and authentication services, testing tools, data storage, automated processes and analytics, marketing and advertising, email or other communication services, development and research or actuarial studies, customer support, and tax, accounting, and legal services.
Marketing and Advertising Partners. We may also disclose your Personal Information with our marketing and advertising partners to send you content about certain products and Services.

We also may disclose your Personal Information in the following circumstances:

Business Transfers. If our assets or equity are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, refinancing, reorganization, or in preparation or contemplation for any of these events, we may transfer the Personal Information we have collected from you to the other company.
In Response to Legal Process. We also may disclose the Personal Information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena, or to comply with national security or law enforcement disclosure requirements.
To Prevent Fraud and Protect Us and Others. We also may disclose the Personal Information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy or our Terms of Use, or as evidence in litigation in which we are involved. We may also disclose Personal Information to protect our rights and the rights of others. This may include exchanging information with other companies and organizations for fraud prevention, spam/malware mitigation, and similar purposes.
Aggregate and De-Identified Information. We may disclose aggregate or de-identified information about users with third parties for marketing, advertising, research or other purposes.
With Your Permission. We may disclose Personal Information in other ways not described above. If we do so, we will notify you and, if necessary, obtain your consent.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Our legal basis for collecting and processing Personal Information depends on the Personal Information involved, the context in which we collect it and the applicable laws and regulations. Generally, we collect Personal Information from you where: we have your consent to do so; we need the Personal Information to perform a contract with you (for example, your subscription to one of our Services) where permitted under applicable data protection laws; or, in some jurisdictions such as the European Economic Area (“EEA”), the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms or the processing is otherwise consistent with applicable law. In some circumstances, we are required by law to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will inform you whether the provision of your Personal Information is mandatory and the possible consequences if you do not provide your Personal Information. Where we send you marketing or promotional e-mails regarding our Services from our affiliates, we do so based on your consent if required by applicable law. If we collect and use your Personal Information in reliance on our legitimate interests or those of a third party, this interest is to provide our Services to you and for our legitimate commercial interest such as responding to your inquiries, improving our Services, processing payments, advising you of product features or new releases, providing training, or engaging in marketing activities.

COOKIES AND OTHER TRACKING MECHANISMS

We and our third-party providers may use cookies, pixels, web beacons, tags, and other similar mechanisms to gather information when you interact with our Services. We may automatically collect information about browsing activity, type of device and similar information within our Services and to target advertising and content across our Services and third-party sites and services. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services.

Where permitted by applicable law, we will deploy first and third party performance or analytics Cookies automatically when you visit our websites. Where required by applicable law, we will obtain your consent before we place any Cookies on your device that are not strictly necessary for the functioning of our websites. To learn more about how we use such technologies, including about how to consent to or opt-out and withdraw your consent to Cookies, please see our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Sites and Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

Controls for Do Not Track.

We do not currently respond to Do-Not-Track (“DNT”) browser signals.

Your Cookie and Marketing Choices

We make available several ways for you to manage choices about your Personal Information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information.

Cookie Settings. If you wish to prevent cookies from tracking your activity on our Sites or visits across our Services, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Sites, but some features may not function. You can also manage your cookie preferences in our Cookie Settings.
Industry Ad Choice Programs. You can also control how participating third-party ad companies use the Personal Information that they collect about your visits to our websites and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA App Choices tool (https://youradchoices.com/appchoices) in order to help control interest-based advertising on apps on your mobile device.
Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you.
Account and Profile Information. You may also access, update, or correct your account and profile information at any time by logging in to your account and updating the Personal Information we maintain. We may keep a copy of your prior information for a period of time, as part of our business records and our backup data.

Children’s Information

Our Services are not learn that we have received information directly from a child who is under the age of 16, we will delete such information from our systems. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

Blogs and Other Interactive Features

We may offer blogs, online forums or other interactive features on the Services that enable you to share information about our Services or other issues of interest. You should be aware that any communications you submit or post to any such interactive features on the Services may be viewable by other participants or users. Therefore, by submitting or posting to such interactive features you acknowledge that you have no expectation of privacy or confidentiality in the content you submit for such features, whether or not it contains Personal Information about you.

External Links

When you use our Services, you may find links to other websites and webpages that we do not control. We are not responsible for the contents of those websites or any other aspects of these-party sites, including their collection of your Personal Information. You should review third-party terms and conditions and privacy policies before providing your information.

Security

We have implemented safeguards designed to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

International Data Transfers

Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (please see above), including facilities in the United States, and other countries.

YOUR DATA PROTECTION RIGHTS

Depending on which laws apply to your Personal Information, you may have the right to make the following requests regarding your personal information:

Access to Your Personal Information. You may request access to your Personal Information, confirmation that we have information about you, or information about our processing of your Personal Information which may include, depending on your jurisdiction the right to request: the categories of Personal Information we process or have processed about you, a list of the specific third parties with whom your Personal Information was disclosed, or access to your data in a portable, machine-readable format. Some jurisdictions also provide you with the right to request the categories of Personal Information sold or disclosed for a business purpose and categories of third parties to which Personal Information was sold.
Deletion of Your Personal Information. You may request that we delete your Personal Information. If required by law, we will grant a request to delete information, but note that in many situations we may retain Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
Corrections to Your Personal Information. We rely on you to update and correct your Personal Information. Where your Personal Information is required to access or use Services, you may have the opportunity to correct, update, or modify this information by logging into your account and updating your information online. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
Objection to Certain Processing. Under certain circumstances and certain applicable local laws, you may object to our use or disclosure of your Personal Information.
Obtain a Copy of Your Personal Information (Data Portability). You may have a right to obtain a copy of your Personal Information in a structured, commonly used, and machine-readable format where the Personal Information was provided by you and processed pursuant to the fulfillment of a contract with you or on the basis of your consent.
Consent to Our Use of Cookies That Are Not Strictly Necessary. In jurisdictions where required by law, we will obtain your prior, opt-in consent before using cookies such as data analytics and targeted advertising cookies. We are not required to obtain your consent to use strictly necessary cookies that are needed for the basic functioning of our .
Consent to Our Processing of Sensitive Personal Information (“special categories of personal data”). In jurisdictions where required by law, we will obtain you prior, opt-in consent before processing (collecting, using or sharing) your sensitive personal information.
Restrict Processing. Under certain circumstances and certain applicable local laws, you may request that we restrict our processing of your Personal Information under certain circumstances, such as when you contest the accuracy of our records about you, or you make an objection.
Revocation Of Consent. Where we process your Personal Information based upon consent, you may revoke consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted before withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. Please note, if you revoke your consent for the processing of your Personal Information then we may no longer be able to provide you Services.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, because a right is not granted by the laws that apply to a specific person, or if we are unable to adequately verify your identity. Individuals in certain jurisdictions may have other rights. For more information, see the applicable jurisdiction-specific addendum which forms part of this . We will not retaliate against individuals who exercise their privacy rights under applicable law. Other than California’s privacy law, state privacy laws in the Unted States do not apply to us because we do not market or sell our products and services to individuals for their personal and household use. We market and sell commercial products and services to businesses. If you are a California resident, please see the Additional Notice to California Residents section below for more information.

You may use this Personal Information Request Form or call us at 1-800-714-9645 to exercise any of your rights. If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal,” at CorporateComm@SolomonInsight.com.

We respond to requests we receive from individuals wishing to exercise their data protection rights or express any concern in accordance with applicable data protection laws, which typically require a response within 30 days in jurisdictions outside of the U.S. Required response timeframes may vary in other jurisdictions and we will adhere to the required timeframes in those jurisdictions. Please be aware that in order to accommodate some requests, we must verify your identity before we can respond.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must provide all requested information establishing your authorization as an agent to act on another person’s behalf where permitted by applicable law. If you are not satisfied with our response, you may in certain states or jurisdictions have the right to lodge a complaint with your local regulator or supervisory authority.

If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Please note that in certain jurisdictions we may be entitled to charge a fee in connection with the exercise of these rights, which will be communicated to you if applicable.

Changes to This Policy

This Policy is current as of the date Last Updated set forth above. We may change this Policy at any time and from time to time. Any amendments or modifications to this Policy will become effective immediately upon posting. Your continued use of any of our Services following the posting of a revised version of this Policy will constitute your acceptance of the revised Policy. If you do not agree with the revised Policy, do not use any of our Services.

Contact Us

If you want to submit a verified request regarding the rights above concerning your Personal Information click or call us at +1-800-714-9645.

If you have questions about this Policy or our privacy practices, you may also send a letter or email to the address below.

HSB Solomon Associates LLC

Attn: Corporate Communications

International Plaza III
14241 Dallas Parkway
Suite 1000
Dallas, TX 75254

Phone: +1-800-714-9645

Email: CorporateComm@SolomonInsight.com

Consent

By using the Services or by consenting using a consent mechanism where provided you signify your consent to this Policy and this site’s Terms of Use. If you do not agree to this Policy or the site’s Terms of Use, please do not use the Services. The Services are not for use within any country or jurisdiction or by any persons where such use would constitute a violation of law. If this applies to you, you are not authorized to access or use any of the Services.

We also recognize Global Privacy Control (GPC) signals and other user-enabled opt-out preference signals as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. To learn more about the GPC, you can visit its website here.

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

If you would like to exercise your rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, as amended ("CCPA"), please visit us at our Data Subject Request web page or call us at the following toll-free telephone number 1-800-714-9645.

You can find Solomon’s CCPA Notice at Collection below.

This section of our Privacy Policy provides additional information for California residents pursuant to the CCPA and applies to “Personal Information” as defined in the CCPA, whether collected online or offline. This section of our Privacy Policy when you visit our Sites or otherwise interact or engage with us through our Services that display or include a link to this Policy (collectively, the “Services”). As used in this Additional Notice to California Residents, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Service Provider

Solomon may sometimes act as a service provider under the CCPA. This means that we collect and use Personal Information on behalf of another company. Where your Personal Information is processed by Solomon acting as a service provider, that other company’s privacy policy will explain its privacy practices, and you should submit any request to exercise CCPA rights directly to that company. If you make a request to exercise CCPA rights to Solomon where it acts as a service provider under the CCPA, we may be required to disclose your request to the relevant company.

Personal Information Not Covered by this California Section of the Privacy Policy

There are a number of exemptions from the application of the CCPA. The following sets out some of the categories of Personal Information that are not subject to the CCPA and therefore are not covered by this California section of the CCPA and Policy. Note that other sections of the Privacy Policy may still apply in addition to other privacy notices that we may issue addressing our specific relationship with you.

Health or medical information that we collect and that is subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Confidentiality of Medical Information Act or the Health Information Technology for Economic and Clinical Health Act.
Information we collect in connection with the issuance of financial products or services to you that are to be used primarily for your personal, family, or household purposes and that is subject to the Gramm-Leach-Bliley Act (“GLBA”) or the California Financial Information Privacy Act. Note that this exclusion may not apply to all of your Personal Information, including to personal information collected before you become a customer.
Information we collect and provide for use that is subject to the Fair Credit Reporting Act.
Information we collect as a motor vehicle record and that is subject to the Driver's Privacy Protection Act of 1994.
Publicly available information from government records, and information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
Deidentified or aggregated information.

California Notice at Collection

Categories of Personal Information We May Collect

The following identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months). Note that our collection, use and disclosure of Personal Information about you will vary depending upon the circumstances and nature of our interactions or relationship with you. Depending on how you use our Services, we may collect the following categories of Personal Information:

Identifiers, such as real name, alias, job title, postal address, unique personal identifier, online identifier, internet protocol (IP) address, device IDs, ad IDs, cookie data, email address, date of birth, salary information, social security number, driver’s license number, other government identifiers, credit card number, and tax ID.
Commercial Information, such as records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Financial Information, such as credit card information, payment account details, billing information, shipping information, and any other information required in connection with fulfilling purchase orders.
Characteristics of Protected Classifications under California or Federal Law, such as age (40 years or older), race, ancestry, national origin, citizenship, religion or creed, marital status, pregnancy, medical condition, physical or mental disability, sex, sexual orientation, and veteran or military status.
Usage Data, such as Internet or other electronic network activity information regarding a interaction with portals, Internet websites, applications, or advertisements, including, but not limited to, browsing history, clickstream data, search history and content of public posts.
Biometric Information, such as individual biological or behavioral characteristics including measurements of physical characteristics such as height, weight and blood pressure, sleep, health, or exercise data that contain identifying information.
Education Information, such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes and student disciplinary records.
Geolocation Data, such as physical location.
Audio, Video and Other Electronic Data, such as audio information including call recordings, video and photographs, and recorded meetings and webinars.
Professional or Employment-Related Information, such as business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
Inferences and Preferences, such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behavior and abilities.
Sensitive Personal Information, such as social security number, driver’s license number, racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, medical condition, and physical or mental disability.

Sources of Personal Information

We generally collect Personal Information from the following categories of sources:

Directly from you and automatically;
Our affiliates;
Our vendors and service providers.

For more information about sources of Personal Information, please refer to the section of our general Privacy Policy above PERSONAL INFORMATION WE COLLECT.

We may disclose for a business or commercial purpose each of the categories of Personal Information described above to the categories of parties described in the section HOW WE MAY SHARE PERSONAL INFORMATION in our general Privacy Policy.

For more information about the business and commercial purposes for which we may collect, use or disclose such information, please review the BUSINESS AND COMMERCIAL PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED AND USED in the general Privacy Policy.

We may sell or share, or have sold or shared the following categories of Personal Information to third parties in the preceding twelve (12) months:

Category A. Identifiers
Category B. Personal information as defined in the California Customer Records law
Category C. Characteristics of protected classifications under state or federal law
Category D. Commercial information
Category E. Internet or other electronic network activity information
Category F. Geolocation data
Category G. Audio, electronic, visual, and similar information
Category H. Inferences drawn from collected personal information

The categories of third parties to whom we sold personal information are:

Ad Networks
Retargeting Platforms
Social Networks
User Account Registration & Authentication Services

Sensitive Personal Information

Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive Personal Information” beyond the purposes authorized by the CCPA. Accordingly, if we use ‘sensitive Personal Information”, we only do so as reasonably necessary and proportionate: (i) to perform our Services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our Services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Retention of Personal Information

We retain the Personal Information we collect only as reasonably necessary for the purposes described in this Privacy Policy or otherwise disclosed to you at the time of collection. For example, we will retain certain identifiers for as long as it is necessary to comply with our tax, accounting and recordkeeping obligations, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and to comply with our legal obligations.

Deidentification of Personal Information

Occasionally, we may deidentify Personal Information and use the deidentified information for our internal purposes. We commit to maintaining and using this information in deidentified form and will not attempt to reidentify the information except to determine whether our deidentification process is effective.

Rights Regarding Your Personal Information

The CCPA provides California residents with specific rights regarding Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights. Subject to certain exceptions, California consumers have the right to make the following requests:

Right to Know: With respect to the Personal Information we have collected about you in the prior (twelve) 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions and carveouts):

The categories of Personal Information we collected about you;
The sources from which we have collected that Personal Information;
Our business or commercial purpose for collecting, selling, or sharing that Personal Information;
The categories of third parties to whom we have disclosed that Personal Information; and
A copy of the specific pieces of your Personal Information we have collected.

Right to Correct. Subject to certain restrictions, you have the right to request that we correct inaccuracies in your Personal Information.

Right to Delete. Subject to certain conditions and exceptions, you have the right to request deletion of your Personal Information that we have collected about you.

Right to Opt-Out. We “sell” and “share” Personal Information under the CCPA.

To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, please click here or use the Do Not Sell or Share My Personal Information link at the bottom of our website.

You also have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA, including through the use of an opt-out preference signal. If our Site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC— signal, we will opt that browser or device out of cookies on our Site that result in a “sale” or “sharing” of your Personal Information. If you come to our Site from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information other than for limited purposes permitted under the CCPA and, as such, are not required to offer consumers a right to limit its use.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Rights

If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

Accessing our Data Subject Request web page; or
Calling us at 1-800-714-9645

Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that you directly verify your identity and the authority of your authorized agent.

Businesses operating as an authorized agent on behalf of a California resident must provide both of the following:

(1) Certificate of good standing with its state of organization; and
(2) A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the business to act on behalf of the California resident.

We reserve the right to reject (1) authorized agents who have not fulfilled the above requirements, or (2) automated CCPA requests where we have reason to believe the security of the requestor’s personal information may be at risk.

Verification. Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. The information we need in order to verify your identity differs depending on the request made and our relationship with you, and might include (as applicable) your name, the email address your regularly use to interact with us, your phone number, and, if available, your order number. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. In some cases, we may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your Personal Information. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.