Last Updated December 20, 2023
1. Description of services offered by Soleo.
Soleo offers a variety of call management solutions including access to our pay-per-call platform known as CallThread. Features of our services include, but are not limited to: call automation using custom call routing and Interactive Voice Response (“IVR”) menu creation, voicemail, call recording, call transcription, call scoring, call tracking with number porting, number assignment, and call forwarding, real-time reporting dashboards, including third-party plug-ins and integrations, lead generation services including campaign management tools such as geolocation targeting, budget pacing, and a bid strength optimizer tool to determine competitive prices for leads by industry and location against current bid prices paid by competitors. Soleo also offers various telecom carrier-based solutions including, directory assistance, call handling for disconnected numbers, and fraudulent call identification. These features and services are collectively referred to as the “Service(s)”.
2. When and how does Soleo collect Personal Information?
3. Call Recording and Call Transcription.
Soleo offers call recording and transcription features as part of its Services. Any caller placing a phone call to a phone number, assigned by, associated with, or directed to any of our Service platforms for call handling by Soleo should be aware that they could be disclosing Personal Information, including sensitive Personal Information, which may include, but is not limited to, financial account information and medical or health information, during the call. Calls may be monitored and/or recorded and/or transcribed for quality assurance purposes.
Callers are not obligated to disclose any Personal Information while using any of Soleo’s Services and should be aware they are solely responsible for any disclosures of Personal Information, including sensitive Personal Information, they may make during any calls handled by Soleo. You are responsible for communicating this information to your customers who may use our Services.
4. What Personal Information does Soleo collect?
We may collect the following Personal Information from you or your customers, on your behalf, when interacting with our sites or Services:
- your name or the name of your customers;
- the name of your business;
- your job title and employer;
- your phone number or your customer’s phone number;
- the phone number of your business;
- your email address or your customer’s email address;
- the email address of your business;
- the hours of operation of your business;
- geolocation information pertaining to your business or your customers;
- credit card, debit card, bank account or other payment information that you provide to arrange for payment of our Services, directly or indirectly, through our sites or third-party payment processors;
- other details about your business in connection with the creation of your account to help you better utilize our Services;
- survey results;
- lists of products or services ordered by you from Soleo;
- information to validate your identity in case you forget a password or username to your account;
- device-specific information from you or your customers (for example: tablet model, mobile phone model, operating system version, and mobile network information);
- the ISP used by you or your customers;
- the browser type and version used by you or your customers
- your IP address or the IP address of your customers;
- what pages, reports, widgets, and other tools you used in relation to our Services
- any unusual event information such as crashes, errors, slow load times, and other troubleshooting details; and/or;
- other information produced by Cookies or Web Beacons we send to your electronic devices or the electronic devices of your customers;
5. What are Cookies and Web Beacons? How does Soleo use them?
A Cookie is a small piece of data sent from a website and stored locally on your electronic device by your web browser while you are browsing on a site on the internet. Cookies enable Soleo, and third-party sites, to recognize you or your preferences, gain information about your use of our sites or Service, enhance your user experience, and help us improve our Services. Some Cookies are automatically deleted at the end of a web session; however, we may use persistent Cookies that remain on your browser after your session is terminated. Some Cookies may provide an opt out option. Soleo does not maintain a process to track opt outs related to Cookies. However, the ‘Help’ option on the toolbar of most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive a new Cookie, or how to disable Cookies altogether. A Web Beacon is similar to a Cookie. A Web Beacon is embedded on a specific website instead of being stored locally on your computer. Web Beacons are used to track your online behavioral movements and internet use. Soleo may use Web Beacons in some of its marketing or promotional materials that it sends to you. We do this by embedding a Web Beacon in the email or landing page we send to you. We can determine who opened or viewed certain messages or landing pages, and in turn improve the quality of our marketing efforts. You can opt out from receiving these messages by clicking the ‘unsubscribe’ link in any marketing communications.
6. Why does Soleo collect Personal Information?
We may collect and use Personal Information for the following purposes
- to communicate with you about the Services we provide;
- to provide you with the Services you register for or sign an agreement for;
- to customize aspects of our Service to fit your needs;
- to maintain, improve, and provide basic functionality of our Services;
- to resolve any support tickets or service requests;
- to publicize campaigns on our call network;
- to send you information on promotions or events;
- to send you newsletters, blogs, white papers, case studies, or other information you may be interested in;
- to transmit information to Soleo’s third-party payment processor for the purpose of completing one or more payment transactions
Additionally, with your consent we may use information about you for a specific purpose not listed above, such as, in marketing materials including testimonials, articles, or other sales related materials use to promote our Services.
7. Will Soleo disclose Personal Information?
- you have given us your permission to disclose the Personal Information;
- to transmit information to Soleo’s third-party payment processor for the purpose of completing one or more payment transactions;
- the disclosure is made to a party that controls or is controlled by Soleo;
- the disclosure is made to a vendor that has been retained by Soleo to provide certain services, including but not limited to, maintenance or performance improvement to any of Soleo’s systems or platforms, marketing services, or data analysis;
- the disclosure relates to the acquisition or sale of certain assets, subsidiaries, or business units between Soleo and another entity. In the event of such transactions, Personal Information collected through our sites and Services may be one of the transferred business assets. We reserve the right to include Personal Information in any such transfer;
- the Personal Information is otherwise publicly available;
- to satisfy a valid order from any court or governmental agency, or to comply with any applicable law or regulation. Soleo will provide reasonable assistance and information, including Personal Information, to any appropriate judicial, law enforcement or government authorities that make a lawful request for such information, and you hereby consent to such disclosure;
- to prevent or investigate any potential illegal activity, regardless of the existence of a subpoena, warrant or other valid court order;
- to enforce or investigate violations of the Terms of Service, Publisher Terms of Service, or any other agreement in place between you and Soleo;
- to respond to access or deletion requests of Personal Information from you or your customers;
- to protect the rights, property, or safety of Soleo, its users or the general public.
8. How does Soleo protect Personal Information?
Soleo undertakes several precautionary measures to maintain the security of all sites and platforms related to our Services and the collection and storage of Personal Information. Personal Information is stored on secure servers at secure locations. Soleo protects Personal Information online by ensuring that our third-party data center service provider(s) use industry standard encryption methods to prevent unauthorized access to Personal Information stored on our servers and platforms as well as conducting pen testing to prevent attacks from hackers. Additionally, Soleo uses PCI-compliant payment processing vendors. Soleo protects Personal Information offline through the use of restricted access protocols that limit access to our facilities and systems that contain Personal Information to authorized personnel that require access to the Personal Information in order to fulfill their duties. We also have procedures in place to handle any suspected or actual data breaches in the rare and unlikely event that a breach occurs. However, you should be aware that the nature of the Internet is such that we cannot guarantee or warrant with absolute certainty the security of any Personal Information transmitted to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. We do take commercially reasonable efforts to protect Personal Information in our possession.Soleo may store and process Personal Information in any state or country in which Soleo or its third-party vendors maintain facilities, including outside of the state or country from which such consent to obtain Personal Information first originated. The privacy laws in the jurisdiction where your Personal Information is stored may be different from the privacy laws where you live. If you are located outside the United States and choose to provide information to us, please be aware that we may transfer Personal Information to the United States and process and store it there. As a result, your information may be subject to access requests from governments, courts, and/or law enforcement officials in the United States. By accessing any of our sites and using our Services you consent to the transfer of your Personal Information outside of your state and/or country.
9. What about links to third-party sites or applications?
10. Social media platforms and other public forums?
12. How long is your Personal Information retained by Soleo?
13. How can you access your Personal Information?
14. Can I opt out from providing my Personal Information?
You must provide your Personal Information to do business with Soleo, however, providing such information is purely voluntary. If you do not wish to provide Personal Information simply decline or terminate contact with Soleo, its sites and Services. Please note, if you do not wish to provide certain Personal Information it may limit your ability to use the Services Soleo is able to offer to you. Our primary intent in collecting and using the Personal Information you provide to us is to deliver the Services you request. Soleo may use your Personal Information to communicate with you in relation to the Service, or on occasion to send you information related to any planned or unplanned Service outages. You agree that we may contact you with important updates about your account or Service. You do not have the option to opt out of such communications as they are tied directly to the Service. Additionally, Soleo may also use the Personal Information collected for marketing purposes. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Such interest can be shown through opening emails from us or the date you last used any of your accounts to access our Services. If you wish to opt out of receiving such marketing related commutations simply click the ‘unsubscribe’ link in the promotional communication.
15. California Residents – California Consumer Privacy Act (CCPA).
- You have the right to access your Personal Information that we have collected, used, disclosed, or sold, including the right to receive, once per year, the following information:
- Categories of Personal Information about you that we collected in the preceding 12 months and the source of such Personal Information;
- Commercial purpose we collected, used, disclosed, or sold your Personal Information;
- Third parties to whom we have disclosed or sold your Personal Information to in the preceding 12 months.
- You have the right to request that we delete any of your Personal Information in our possession.
- You have the right to opt out from the collection of your Personal Information as well as any marketing communications that are not required as part of the provision of any Services to you.
How to Exercise Your Rights Under the CCPA
16. EEA Residents – General Data Protection Regulation (GDPR).
Lawful Basis for Controller and Processor ActivitiesIf you are an individual in the European Economic Area (EEA), we may collect and process Personal Information about you or any Data Subject, as defined under the GDPR, where we have legal basis for doing so. Personal Information under this Section shall have the meaning assigned to Personal Data under the GDPR.We may collect your Personal Information for the following reasons
- We need it to provide Services to you, including providing customer support, personalized features, or to protect the security of our platforms;
- You give us consent to do so for a specific purpose such as using our sites or Services.
By using any of our sites or Services you consent to our collection, use, disclosure or transfer of your Personal Information. If you have consented, you have the right to change your mind at any time, but this will not affect any processing that has already taken place and you may no longer be able to access our sites or Services after you withdraw consent.
Role as Controller or Processor
Location and Data Transfers
Soleo is based and operated in the United States. We may transfer any of your Personal Information we collect, use, store, or process to the United States or to any other country where a Soleo affiliate or third-party vendor is located for the purpose of processing or storage. Any such affiliate or third-party vendor shall be contractually obligated to meet the requirements of a Processor under the GDPR. For any transfers of Personal Information to the United States, we take industry standard precautions to ensure the protection of such Personal Information through use of administrative and physical security measures. If you or your organization are required to enter into a Data Processing Agreement including Standard Contractual Clauses with your Processor pursuant to the GDPR, please contact [email protected]. By using our sites and Services, you, and any Data Subject under the GDPR expressly consent to the collection, use, transfer, and processing of Personal Information outside of the EEA. Rights of Data SubjectsPursuant to the GDPR, Data Subjects have the following rights:
- Access to his/her Personal Information
- Rectification of Personal Information meaning a Data Subject may correct or supplement Personal Information
- Restrict or suspend processing of his/her Personal Information
- File a complaint to the supervisory authority in his/her EU state
- Object to processing of his/her Personal Information, including for direct marketing purposes
- Receive his/her Personal Information in a standard electronic format for data portability purposes
- Erasure or deletion of his/her Personal Informatio
- Withdraw Consent previously granted in relation to collection of Personal Information
Exercising Your Rights
17. Age Restrictions
You must be at least 18 years old to access our sites and register for our Services. Our sites and Services are compliant with the Children’s Online Privacy Protection Act and are not targeted, designed, or intended to collect Personal Information from children under the age of 13. Soleo does not knowingly collect Personal Information from children under the age of 13. If you are under 13, you are strictly prohibited from using our sites, registering for our Services, making any purchases through our sites, using any of the interactive or public comment features on our sites, or providing any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13, without verification of parental consent, we will delete that Personal Information. If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us at [email protected] and we will use our best efforts to respond to your request and delete any Personal Information within a reasonable timeframe
18. Contacting Soleo