Privacy Policy

Solaris Paper, Inc., including its direct and indirect subsidiaries, parents and brands, such as FIORA, and affiliates (collectively, “Solaris”, “us” “our,” or “we”) are concerned about online privacy issues and want you to be familiar with how we collect, use and disclose any personal information that individually identifies you (e.g., your name, address, phone number, IP address, e-mail address, etc.). We developed this privacy policy to explain how we treat your personal information that we gather from or about you, whether digitally, in writing, in person, or otherwise.

As used in this privacy policy (the “Privacy Policy”), the term “personal information” follows the definition of “Personally Identifiable Information” (“PII”) used by the White House’s Office of Management and Budget (“OMB1”) . We will only collect, use and disclose your personal information in accordance with this Privacy Policy. In certain cases, local jurisdictions (e.g., states, cities, etc.) will require more restrictive treatment of personal information. When that happens, we will respect the additional restrictions such jurisdictions require above and beyond this Privacy Policy. As a result, our actual practices may vary depending on your local requirements, particularly for California residents.

This Privacy Policy also explainshow ourpersonal information practices interact with your use of any web page, web site, application or social media related to our United States operations (collectively, “Our Websites”, and each “Our Website”). Websites currently include but are not limited to fiorabrand.com, solarispaper.com, the Fiora Brand Facebook page, Instagram account, and YouTube channel, as well as any other website or social media that we have or may make.

How do we protect personal information?

The security of your personal information is important to us. We maintain commercially reasonable administrative, technical and physical safeguards, each of which may vary depending on the sensitivity of such information. Such safeguards are designed to protect against unauthorized use, disclosure or access of personal information we collect through Our Websites. Unfortunately, however, no data transmission over the Internet can be absolutely guaranteed as fully secure. As a result, we cannot ensure or warrant complete data security.

What personal information do we collect?

We may collect personal information from you when you voluntarily provide it to us (e.g. through Our Website, text, fax, phone, mobile application, third-parties, subsidiaries, affiliates, or otherwise). For example, we may ask you to provide personal information in accordance with our legitimate business interests if you:

  • agree to receive online information from us, such as e-mail newsletters or e-mail updates, from which you may unsubscribe at any time;
  • participate in a review, survey, a consumer research panel, or similar type of activity;
  • conduct business with us, in which case we will,in order to manage your account, collect certain information from you (e.g. at a trade show, through a mobile app, by connecting with us through social networking, on a webpage, etc.);
  • have authorized a third-party to share relevant information about you that may be relevant to your account with us;
  • apply for employment with us or any of our affiliate companies, in which case you would provide personal information contained on your resume or on other submitted materials;
  • contact us through a web portal and provide us with contact information for us to respond to your inquiry;
  • enter into any contest, giveaway or sweepstakes that we may from time to time conduct, in which case we would collect information required to contact and inform participants about the status of their entry;
  • enter into a contract with us or one of our affiliated entities;
  • provide feedback regarding our services or products;
  • file a complaint or incident report explaining a factual scenario that identifies you as someone involved in or who witnesses the thing you are reporting to us;
  • visit one of our facilities equipped with IT or security equipment that permits our security staff to monitor people on the premises;
  • provide us administrative, analytic, security, compliance or other services to support our legitimate business purposes;
  • are involved in our charitable or philanthropic activities (e.g. scholarships, donations, etc.), which requires identifying people and institutions participating in such activities;
  • contact any of our customer service departments, in which case we will ask you for personal information in order to access and service your account; or
  • otherwise participate in features of Our Website that ask for personal information.

In addition, if you otherwise request any information, service or other offering from us, you may be required to providepersonal information in order for us to process your request.

Your participation in any of these activities is voluntary and we will only use the personal information that you provide for the purposes for which it was collected. For example, we may use the personal information you provide us to respond to your questions or comments, fulfill your requests, provide you with services or products, identify your needs or preferences, administer and manage our business operations, or otherwise provide or improve our products and services in accordance with our legitimate business interests.

By contrast, we will not use personal information collected for one purpose for some other purpose. For instance, personal information collected to verify your identity during a phone call with one of our customer service centers would not be used to enroll you in an e-mail newsletter unless you also consent to such enrollment. When it comes to any mailing, newsletter or the like, you will always have the opportunity to “unsubscribe” from such communications at any time you choose.

Do we use Cookies to automatically gather your personal information?

As used in this Privacy Policy, our use of the term “cookies,” includes browser-based cookies, as well aspixels, web beacons and other similar technologies used to track online activity (collectively, “cookies”), on Our Websites. Our cookies generallycollect “other information” that enhances functionality and navigation for our visitors without the use of personal information. But certain categories, such as pixels, do collect personal information meant to provide insights into our userbase.

You can disable or delete cookiesin your web browser but note that doing so may disable certain features of Our Websites. Disabling cookies may also inhibit other websites as well.

Our cookies collect user traffic data for Our Website, enabling us to personalize and improve your experience. We may also embed cookies in e-mail messages, which allow us to, among other things, determine which whether a recipient of an e-mail message opened the message.

Portions of Our Websites may also use statistical tools that third-party providers operate, such as Google (collectively, “Analytical Tools”). Our Analytical Tools help us track general things such as IP addresses, system information, which of Our Websites you visit, and web activity.

In the case of Analytical Tools, the information generated by the cookies or web beacons about your use of Our Websites may be transmitted to and stored on servers of the third-party who provides us with their Analytical Tool. Such servers may reside anywhere on earth, or in multiple locations. Wherever stored, this information will be used for evaluating activity on Our Websites, compiling reports about that activity and providing other services related to such activity. Analytical Tool providers may transfer this information to other third parties, such as if the third parties process information for the provider, or if required by law.By using Our Website, you consent to the processing of data about you by Analytical Tools providers and related third parties in the manner and for the purposes set out above.

Do we share personal information, and if so, how?

We do not share your personal information except as described in this Privacy Policy.That includes us selling, transferring or otherwise disclosing to third parties the personal information that we collect on Our Websites or otherwise. Below is a list of circumstances under which we would share personal information in accordance with this Privacy Policy:

With Your Consent – We may from time to time offer you to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree, we will share your personal information with the third-party. Shared information will then be subject to the privacy notice and business practices of that third party.

Required by law – We may transfer and disclose your information to third parties (i) to comply with a legal obligation, such as when ordered by a court of law to provide your personal information, (ii) when we believe in good faith, such as upon advice of counsel, that the law requires disclosure without a court order, (iii) to comply with a valid subpoena or a government authority conducting a lawful investigation, (iv) to verify or enforce our policies, Terms of Use and other agreements or to protect the rights, property, or safety of Solaris, our customers or others, (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services or the public.

Corporate Affiliates – We may share certain personal information you provide us (e.g. orders, questions, job applications, etc.) within the Solaris family of companies and with our affiliates. Our corporate affiliates include any person that controls, is controlled by, or is under common control with us. Sharing personal information with corporate affiliate can be used for fulfilling orders, marketing, recruitment, internal reporting, and other purposes related to our legitimate business interests. Doing this is for efficiency, to better understand our customers, and to monitor how our affiliates are serving our customers.

Business Transfers – It is possible that another company might in the future purchase us in whole or in part2. If that were to occur, disclosing personal information would be required for the purchase to continue the business and to maintain your account.We would thus disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants involved in the transaction or transactions. If we transfer your information to an acquirer, we will use reasonable efforts to ensure that such acquirer either adopts this Privacy Policy or has in place its own such policy with substantially similar provisions in order to protect your personal information. A similar disclosure of personal information would occur if we were to enter into bankruptcy. A bankruptcy or reorganization proceeding that is brought by or against us could require your information to be transferred as a company asset that may be sold or transferred to third parties.

Marketing Partners – We may share personal information within our network of advertising companies and publishers, who collect personal information on our sites. Our business partners may also combine your personal information with their data in order to send tailored promotional communications to you using the combined set of information. If you prefer not to receive these joint communications, you can opt out by following the instructions included in any such communication.

Non-Personal Information – We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties. This information contains no personal information.

Third-Party Services – We don’t do everything in-house. Some services we provide are contracted out to third-party services who host or operate Our Websites, analyze data for us, provide customer service, mail product samples or manage payments, provide advertisements, sponsor or promote us, conduct e-commerce, host giveaways or conduct contests (such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list), or assist with risk management, compliance, legal and audit functions. Sharing personal information with such service providers enables the services we require to be performed as part of our legitimate business interests. Ourservice providers may not use or disclose personal information except as necessary to perform services or to comply with legal requirements.

Links to other websites

Our Websites may contain links to other websites operated by third parties. Any such websites are wholly independent from Our Websites, and we have no control over those websites, their operators, their security, their privacy policies or their practices. Before providing any of your personal information on any such other website, you should review the policies on privacy and security for such website.

Automated decisions about you

We may use certain algorithms or other technologies to assist our employees with the task of sifting through large amounts of data that could be impracticable for manual review. For instance, if a certain job opportunity were to receive many applicants, we may use an automated service to algorithmically sort the data set in order to provide our employees with only the most relevant applicants for the position in question. Similar technology may be used in other circumstances unrelated to employment. Such technology, however, is not guaranteed to be flawless, and we are willing to review things called to our attention. You can always contact with questions or objections regarding an automated decision about you, or to request that an automated decision be reviewed manually by a person.

Interactive features and social media

Using social media or interactive features on Our Websites (e.g. Facebook or Twitter feeds, comment sections, chat rooms, etc.) comes with certain risks and is not subject to this Privacy Policy. If you voluntarily post or otherwise disclose personal information, you make it available for others to view, collect or use at your own risk.

We have no control over how others might use personal information that you choose to make available online. Voluntarily making your personal information available online can have many consequences stemming from parties other than us, none of which we control (e.g. unsolicited messages, sharing of your personal information, etc.). We undertake no obligations as to the security of information you voluntarily post using social media or interactive on Our Websites.

For how long do you keep my personal information?

We keep your personal information during our relationship and for a limited time afterward. Once our relationship ends, we will retain your personal information in order to:

  • Maintain business records for analysis or audit purposes
  • Comply with record retention requirements under the law
  • Defend or bring any existing or potential legal claims
  • Address any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

What control do I have over my personal information?

You may have certain rights regarding the personal information we keep about you, subject to local law. These may include, among other things, the rights to:

  • access your personal information;
  • correct the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • withdraw your consent for us to use your personal information;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • submit a complaint with your local data protection authority.

Please contact us to update or correct your information if it changes or is inaccurate. When you contact us for this purpose, note that we may require you to provide certain information in order to confirm your identity, which helps prevent others from wrongfully accessing your personal information. We will respond to you within a reasonable time if you contact us, and we will do so within time limits established by applicable law.

What about the children?

Our services are not directed to children under thirteen (13) years old. We do not knowingly collect personal information from anyone younger than thirteen (13) without parental consent. If you become aware that we have collected personal information from a child younger than the age of thirteen (13) without parental consent, please let us know so we can take appropriate action.

United States only

Our Websites are intended for the use by residents of the United States of America only. All matters relating to Our Websites are governed by the laws of the State of California, any other state in which we operate, and the federal laws of the United States of America applicable therein. If you are located outside of the United States of America, and you contact us, please be advised that any personal information you provide to us may be transferred to other jurisdictions where our servers are located and that by submitting information, you authorize its transfer.

What if I’m a California resident?

Then this section on California privacy applies to you, but everyone is encouraged to read this section regardless of where they live. For California residents, please carefully review our California Consumer Privacy Notice (the “California Privacy Policy”), which is applicable solely to the personal information collected online and offline of California consumers who are not Solaris employees, applicants, contractors or other of our personnel.

This California Privacy Policy addresses the relevant notice requirements of the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100,et seq. (the “CCPA”), and certain terms used herein have the meaning given to them in the CCPA.  Nothing in this California Privacy Policy is intended to contradict or limit the applicability of the information provided in our general Privacy Policy.

Notice of collection and use of personal information

We may collect the following information about you.

Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier), cookies, beacons, pixel tags, mobile ad identifiers and similar technology, telephone number, online identifier, internet protocol address, email address, account name, and other similar identifiers

Additional Data Subject to Cal. Civ. Code § 1798.80: Education, credit card number, debit card number, and other financial information

Protected Classifications: Characteristics of protected classifications under California or federal law, such as national origin, age, sex, gender, marital status, religion, ancestry, and veteran status

Commercial Information: Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

Geolocation Data: Information about physical location

Sensory Information: Audio, electronic, visual, and similar information

EmploymentInformation: Professional employment information

Inferences: Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use the categories of personal information listed above for the purposes described in our general Privacy Policy. In addition, we may use such categories of personal information for certain business purposes specified under the CCPA, including as described in this table:

PURPOSES CATEGORIES OF PERSONAL INFORMATION
Performing services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Inferences
Auditing: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences
Short Term Use: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences
Security Purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Inferences
Debugging: Debugging to identify and repair errors that impair existing intended functionality
  • Identifiers
  • Online Activity
Internal R&D: Undertaking internal research for technological development and demonstration
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Inferences
Safety: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
  • Identifiers
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information

Prior collection, use and disclosure of personal information

We may have collected and used your personal information, as described above, during the 12-month period prior to the effective date of this California Privacy Policy. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

Sources of personal information

We may have obtained personal information about you from various sources, including those described below.

CATEGORIES OF SOURCES OF DATA COLLECTION CATEGORIES OF PERSONAL INFORMATION
Directly from you, such as when you make a purchase, register on Our Websites, connect to us via social media, send us questions, requests or comments, participate in market research activities or contests, sweepstakes and similar activities, elect to receive business alerts, newsletter and other communications, when you provide information about an incident or allegation, when you apply for a scholarship, grant or award or take part in our Influencer Program
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Inferences
From your devices, such as when you visit Our Websites
  • Identifiers
  • Online Activity
  • Geolocation Data
  • Inferences
Our parent, subsidiary and affiliated entities
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Employment Information
  • Inferences
Social networking services
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences
Online advertising companies
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Employment Information
  • Inferences
Consumer data vendors
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Inferences
Public databases
  • Identifiers
  • Protected Classifications
  • Online Activity
  • Geolocation Data
  • Employment Information
  • Inferences
System Generated Data
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences

Sharing of personal information

We may have shared your personal information with certain categories of third parties, including as described in our general Privacy Policy and in as shown on the table below.
CATEGORIES OF THIRD PARTIES CATEGORIES OF PERSONAL INFORMATION
Our parent, subsidiary and affiliated entities
  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Sensory Information
  • Employment Information
  • Inferences
Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Inferences
Law enforcement agencies, courts, regulators and government authorities
  • Identifiers
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Inferences
Marketing partners (including network advertising companies, social network advertising, publishers and business partners)
  • Identifiers
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences
Data analytics providers
  • Identifiers
  • Commercial Information
  • Online Activity
  • Geolocation Data
  • Inferences

Sale of personal information

We do not sell your personal information in exchange for monetary compensation or any other valuable consideration.

Disclosure of personal information for business purposes

We may have disclosed to third parties the following categories of personal information for a business purpose: Identifiers, Additional Data Subject to Cal. Civ. Code § 1798.80, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, and Inferences.

California consumer privacy rights

You have certain choices regarding our use and disclosure of your personal information, subject to relevant exceptions under applicable law, as described below.

Access: You may have the right to request, twice in each 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Shine the Light Request: If you are a California resident and have provided us with your personal information, you may ask us to refrain from sharing your personal information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes.

How to Submit a Request

To submit an access or deletion request, see the “How to Contact Us” section at the bottom of our general Privacy Policy. To submit a Shine the Light request, contact us as described in the “How to Contact Us” section of our Privacy Policy.

Verifying Requests

To help protect your privacy and maintain security, we will ask you to provide personal information used to verify your identity before granting you access to your personal information or complying with your request. This applies to your requests to access to or delete your personal information. We may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent with written permission, and (2) verify your own identity directly with us as described above.

Additional Information

We are not permitted to retaliate against you with retaliatory treatment if you choose to exercise any of your rights under the CCPA. We may, however, charge a reasonable fee to comply with your request. This California Privacy Policy is available in alternative formats upon request by contacting us.

Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy in our sole discretion at any time. Please check back from time to time to ensure that you are aware of any updates or changes in this Privacy Policy. Your continued access or use of any of Our Websites after any such changes constitutes your acceptance of the Privacy Policy as revised.

How to contact us

Please contact us using the information below if you have questions, comments or concerns about our Privacy Policy or a related policy, as well as if you would like to do any of the following things:

  • see personal information that you have already sent us so that you can correct, update or delete your personal information from our files;
  • have us delete personal information about your child who is younger than thirteen (13) years old;
  • ask that we not send you mailings or otherwise contact you; or
  • report any violation of this Privacy Policy.

Solaris Paper, Inc.
Attention: General Counsel
100 S Anaheim Blvd., #280
Anaheim, CA 92805
feedback@fiorabrand.com

SIGN UP FOR THE LATEST NEWS AND OFFERS FROM FIORA®

WE PROMISE NEVER TO SHARE YOUR PERSONAL INFORMATION