Effective Date: March 6, 2025

Sola Security Inc., its affiliates, and subsidiaries (“Sola” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how Sola collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals may have regarding such personal information.

For additional information about the privacy choices you may have regarding your personal information, please review the Your Privacy Choices section below. 

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms and Conditions, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

1. Scope

2. Personal Information Collected

3. How We May Use Personal Information

4. Disclosures of Personal Information

5. Cookies and Other Tracking Mechanisms

6. Your Privacy Choices

7. External Links and Features

8. User Generated Content

9. Children’s Privacy

10. Security

11. Changes to this Policy

12. Contact Us

1. Scope
   Except as otherwise described below, this Policy applies to our online personal information processing activities including, but not limited to: visitors to our website where this Policy is posted, including https://sola.security (the “Site”); individuals who sign up for, or create an account with us to access and use our platform available at https://app.sola.security; individuals who register for or participate in our events, surveys, research, or promotions; individuals who subscribe to receive news, information, and marketing communications and materials from us; current, former, and prospective business partners, and service providers; and individuals who communicate or otherwise interact or engage with us or the services available through our Site or other online services (collectively referred to as the “Services”).
   
   You are not under any legal obligation to submit personal data to Sola. However, if you choose not to do so, certain Services might not be available to you. 
   
   This Policy applies to the extent we process personal information on our own behalf, as a controller or business. For certain aspects of the Services (e.g., the Sola platform), we act as a processor to our customers (other businesses) and therefore our processing of personal information is at their direction and subject to our data processing addendum.
   
   Additional Notices. Depending on how you interact or engage with us, we may provide you with additional or supplemental privacy notices. These additional notices will control to the extent there is a conflict with this Policy. For example, this Policy does not apply to the personal information we collect and process about job applicants and candidates for employment with us, or to employees or contractors with whom we work.
2. Personal Information Collected
   We collect personal information directly from you, from third-party sources, and automatically through your use of the Services. To the extent permitted by applicable law, we may combine the personal information we collect from publicly available or third-party sources. The personal information we collect varies depending upon your use of our Services and our interactions with you.
   
   Personal Information Collected Directly. We may collect the following personal information directly from you:
   • Communications and Interactions. When you communicate or interact with us or our Services, including if you sign up for our newsletter, complete forms on our Site, interact with our social media pages, post a product review or testimonial, submit content to the Services, or otherwise engage with us or our sponsored content, we may collect your name, email address, or other similar identifiers, as well as your message, the nature of your inquiry, and any other information you choose to provide.
   • Account and Profile Information. When you sign in or create an account in connection with our Services, we may collect your name, email address, username and password, company, role/title, photograph, as well as any other information used in connection with accessing your account or that you otherwise submit to us through your account. We may also create a user ID for you when you create an account.
   • Purchases and Payments. When you make a purchase or payment through our Services, we may collect information such as payment type, payment card details, billing information, purchasing information, and any other financial or commercial-related information necessary to enable our Services.
   • Chat Function or Virtual Assistant. We may collect information you submit through our chat functions and/or virtual assistants we make available through the Services. We and any service providers we use to administer these features may monitor and record your communications with us and we and these providers may also maintain communication records regarding information provided to us.
   • Promotional Information. If you agree to receive marketing communications from us, we may collect your contact details, preferences, and if relevant, information about your account and profile, including the Services and features you use.
   • Events and Registration Details. We also may collect personal information related to your participation in our events, as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. 
   • Preferences and Other Requests. We may collect information about your preferences, including communications preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.
   • Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective business partners, and vendors and service providers, including contact information and other similar identifiers, company and professional-related information, and communications records.
     
     Personal Information Collected from Third Parties. We may collect and receive personal information from third party sources, such as business partners, data analytics and marketing providers, social media platforms, public databases, customers and other users, and service providers or other third parties who provide services or perform functions on our behalf. We may collect the following information from third-party sources:
     • Employers: We may receive employee information from employers who want us to extend an invite to their employees to join the Sola platform.
     • Referral Information. We may offer users the ability to invite friends or refer other users to access or use our Services. In doing so, we may collect and receive certain personal information about individuals referred to our Services.
     • Integrated Service Information. We may use integrated services that allow you to access, register for, make purchases, or otherwise interact with the Services. If you access or interact with our Services via these integrated services, we may collect or obtain certain personal information from these integrated services. You should check the privacy settings on each integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.
   • Personal Information Collected Automatically. We may automatically collect or derive personal information related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. This may include:
     • Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ad ID, Internet service provider, referring and exiting URLs, clickstream data, and other similar device and browsing information. 
     • Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other similar activity and usage information.
     • Location Information. We also may collect or derive general location information, such as through your IP address. 
       
       For more information about our use of cookies and other similar technologies, please see the Cookies and Other Tracking Mechanisms section below.
3. How We May Use Personal Information
   We may collect, use, disclose and otherwise process personal information for the following purposes:
   • Services and Support. To enable our Services, communicate with you about your use of the Services, provide troubleshooting, technical support, and for similar support purposes, respond to your inquiries, fulfill your requests, and to otherwise run our day-to-day operations.
   • Account Creation and Management. To enable account creation and management, including creating an account on your or your employees’ behalf, or allowing you to create a profile/profiles and set preferences.
   • Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate, develop, and improve our Services and business operations, and for internal quality control and training purposes.
   • Communication. To respond to your questions, send you requested materials and newsletters, as well as information and materials regarding our Services and our offerings. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms and policies.
   • Customization and Personalization. To tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings.
   • Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, to send you promotional information about our Services, including information about sales, discounts, and new offerings, as well any other information that you sign up to receive.
   • Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
   • Insight Development and Data Enhancement. We may combine personal information collected through the Services with other information that we or third parties collect in other contexts to obtain insights into how our Services are used.
   • Planning and Managing Events. For event and webinar planning, and other management-related purposes, such as registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
   • Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service. 
   • Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
   • Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.
   • General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.
4. Disclosures of Personal Information
   We may disclose the personal information we collect for the purposes described above and as follows:
   • Vendors and Services Providers. We may disclose personal information we collect to our service providers, processors, and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, payment processors, analytics providers, consultants, auditors, and legal counsel.
   • Business Partners. Any information that we collect and process on behalf of a business customer will be disclosed to the business customer and otherwise shared as directed by that business customer. 
   • Other Users. We may disclose personal information to other users of the Services to support specific features, or when you request that we do so (implicitly or explicitly). For example, if you use features that allow you to post in areas of the Services accessible to other users, your information may be available to, and searchable by, others. 
   • Third Party Marketing and Analytics Providers. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make personal information available to third parties to support our marketing, analytics, advertising, and campaign management.
   • In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.
   • Compliance and Legal Obligations. We may disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. 
   • Security and Protection of Rights. We may disclose personal information where we believe it is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our terms of service. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
   • Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes. 
   • Other Disclosures. We may disclose personal information in other ways not described above, but will notify you and, if necessary, obtain your consent.
5. Cookies and Other Tracking Mechanisms
   We use cookies, pixels, log files, APIs, and other mechanisms to automatically collect browsing, activity, device, and similar information within our Services and to target advertising and content. We may also engage third-parties or service providers to do the same. We use this information to, for example, analyze and understand how visitors interact with our Services; identify and resolve bugs and errors in our Services; assess, secure, protect, optimize and improve the performance of our Services; conduct marketing and analytics activities; and personalize content in our Services. To manage your preferences regarding cookies, targeted advertising, and other tracking mechanisms within our Services, please see Your Privacy Choices below.
   
   Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service.
   
   Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
   
   Third-Party Analytics and Tools. We use third party tools which are operated by third party companies. These third-party analytics companies may use cookies, pixels, and other similar tools to collect usage data about our Services in order to provide us with reports and metrics that help us evaluate usage of our Services and improve performance and user experiences. Amongst other third-party tools we use Google Analytics. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
   
   Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps, and online services. We may share certain information with these third-party ad companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information.  We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.
6. Your Privacy Choices
   We make available several ways that you can manage your privacy choices and submit privacy requests related to your personal information. Some of these choices are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device used to access our Services. 
   
   These options include:
   • Account and Profile Information. You can review and update some of the personal information we maintain about you by logging into your account and updating your profile information directly within our Services.
   • Marketing Communications. We may send periodic promotional emails or other similar communications to you, in accordance with applicable law. You may opt-out of these communications by following the instructions provided to you in the communication. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences in your account settings.
   • Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, 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 Site, but some features may not function.
   • Browser Signals/Do Not Track. Our Site currently does not respond to “Do Not Track” signals. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Industry Ad Choice Programs section below.  
   • Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site 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). Opting out of participating third party ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
7. External Links and Features
   Our Service may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites, features, or third-party services is not governed by this Policy. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those third-party features or services.
8. User Generated Content
   We may offer interactive features that allow you to create and share information, content, or custom Sola apps with others. Anything you create, submit, or post to any such interactive features on the Services may be viewable and searchable by others. By using these features, you acknowledge that you have no expectation of privacy or confidentiality in the content you submit or create, whether or not it contains personal information about you.
9. Children’s Privacy
   Our Services are not designed for children, and we do not knowingly collect personal information from children under 13. 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 in the Contact Us section below.
10. Security
    We have implemented safeguards intended to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
11. European Economic Area (EEA) Data Subjects.
    1. Legal Basis for Processing of Personal Data. Sola will only process your Personal Data (as defined in the General Data Protection Regulation 2016 /679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“), if it has one or more of the following legal bases for doing so:
       1. Contractual Necessity: processing of Personal Data is necessary to enter into a contract with you, to perform Sola’s contractual obligations to you, to provide the Services, to respond to requests from you, or to provide you with support;
       2. Legitimate Interest: Sola has a legitimate interest to process your Personal Data;
       3. Legal Obligation: processing of your Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
       4. Consent: processing of your Personal Data with your consent.
    2.  Your Rights regarding Personal Data.
       1. Subject to applicable law, you have certain rights with respect to your Personal Data, including the following:
          1. You may ask whether Sola holds personal data about you and request copies of such Personal Data and information about how it is processed.
          2. You may request that inaccurate Personal Data is corrected;
          3. You may request the deletion of certain Personal Data (as long as the Sola does not have a legitimate reason for retaining the data);
          4. You may request Sola to cease or restrict the processing of Personal Data where the processing is inappropriate;
          5. You may request Sola to exercise your right of data portability;
          6. You may contact a supervisory authority in your jurisdiction and file a complaint;
          7. When your consent to processing your Personal Data for a specified purpose by Sola, you may withdraw your consent at any time, and Sola will stop any further processing of your Personal Data for that purpose (to the extent applicable).
          8. In certain circumstances, Sola may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Sola will still respond to notify you of such a decision and you may always appeal in front of the relevant authorities and competent courts.  
       2. You can exercise your Personnel’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Sola at privacy@sola.security. In some cases, Sola may need you to provide Sola with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
    3. Transfer of You’s Personal Data outside of the EEA. 
       1. The data that Sola processes in relation to you may be transferred to, and stored at a destination outside the European Economic Area (“EEA“), e.g., the USA, that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who works for us or for one of our service providers: (i) in order to store it; (ii) where we are legally required to do so; (iii) in order to facilitate the operation of our businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
       2. Where Personal Data is transferred by Sola in relation to providing the services Sola will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, which may include by entering into European Commission approved standard contractual clauses relevant to transfers of Personal Data and that it is treated securely and in accordance with this Policy.
12. Data Subjects Rights under Israeli Law.
    Subject to the Israeli Privacy Protection Law, 1981 and its implementing regulations (“Law”), you have the following rights with respect to your Personal Data (as defined in the Law) processed by Sola, and Sola will act in accordance with the Law, to comply with your requests to exercise your rights: 
    • Right to Review: you have the right to review your Personal Data processed by Sola;
    • Right to Rectification: you may request Sola to correct any inaccurate or incomplete Data processed by Sola;
    • Right to Deletion: you have the right to request the deletion of your Personal Data in the context of direct marketing communications. 
      
      To exercise any of these rights, please contact Sola at privacy@sola.security.
13. Retention
    Sola will retain your Personal Data for a period of time consistent with the original purpose of collection. Sola determines such appropriate retention period based on the amount, nature and sensitivity of the Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data, and whether Sola can achieve the purposes of the processing through other means, as well as on the basis of applicable data protection law requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, Sola will delete your Personal Data. If there is any data that Sola is unable, for technical reasons, to delete entirely, Sola will put in place appropriate measures to prevent any further use of such Personal Data.
14.  International Storage
    We may maintain, store and process personal data in the United States of America, Europe, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law. While privacy laws may vary between jurisdictions, Sola is committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
15. changes
    This Policy is current as of the effective date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on this page. If we make material changes to how we collect, use, or disclose the personal information we have previously collected, we will endeavor to provide you prior notice as required by applicable law, such as by emailing you or posting prominent notice on our website or within the Services.
16. Contact Us
    If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at privacy@sola.security.