Effective Date: August 10, 2018

Last Updated: January 24, 2023

This Privacy Policy (the “Policy”) applies to the websites, applications, and electronic communications on which it appears (the “Platform”). The Policy describes how Soleo Health Holdings, Inc., as well as our affiliates and subsidiaries (collectively “Soleo” or “we” or “us” or “our”), uses the Personal Information that we collect, receive, maintain, and store about you. Please read this Privacy Policy carefully, by interacting with us through the Platform, you consent to this Policy. For information about Soleo’s collection and use of Protected Health Information (PHI), please visit our HIPAA Notice of Privacy Practices at: https://www.soleohealth.com/hipaa-privacy-notice/.

1. Types of Personal Information Collected
We collect a range of Personal Information. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to an individual. When we combine Personal Information with other information (i.e., information that does not, on its own, identify you), we treat the combined information as Personal Information.

Contact and Demographic Information – If you register for a Soleo Connect® account, sign up for our newsletter, or submit an inquiry, we may collect your contact and mailing information. This may include your email name, address, and phone number. We may also collect your age to verify your ability to purchase our products.

Payment Information – If you make a payment through the Platform, we will collect your payment information, including your credit card information and billing address. We will also collect your purchase details.

Employment Information – If you apply for employment with Soleo, we will collect your employment and work history, as well as personal information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.

Account Information – If you create a “Soleo Connect” account with us, you will create and provide us with a username and password and may upload other personal information through our customer portal.

Social Media Information – If you connect to the Platform using third-party social media platforms or connect your account with us to an account on one of those social media accounts, we may include information from that social media account, including your username and password, as well as information from your profile or that you post within the social medial account.

Location Data – While navigating our Platform, your mobile device or browser may share your location data, both through Wi-Fi and GPS. Soleo will collect this information based on the settings of your phone and browser.

Usage Information – We may also collect usage and device information when you visit our Platform. This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, your navigation activity on the Platform, as well as the websites that you came from and the site you visit when you leave.

2. Method of Information Collection
We collect Personal Information in a variety of ways. We collect information directly from you; for example, when you register an account on the Platform, make a purchase, submit a job application, or correspond with us through the Platform.

We also collect information from third parties. For example, we work with business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, and search information providers.

We also collect information from you passively. Our Platform uses tracking tools like cookies, pixels, and beacons. We do this both on our Platform and in emails that we send to you. Through these tools, we collect information about users over time when you use our Platform. This collection includes usage and browser information. We may also have third parties collect Personal Information in this way. For more information about the trackers that we use, please see Section 6 of this Policy. Additionally, if you enable location data on your device, this data will be collected passively based on the location settings on your device.

3. Combining Information
We may combine the Personal Information we obtain. For example, we may combine information that we have collected online with information that we have collected offline, for instance, during calls between you and our support team. We may also combine information that we have collected across other third-party sites or from other third parties with information we already have. Finally, we may combine information across devices.

4. How We Use Personal Information
We will use your Personal Information to fulfill your purchases and offer our services, respond to your requests and inquiries, as well as to send you communications. We also use your Personal Information to communicate with you for transactional purposes. For example, we might contact you about this Policy or our Terms of Use.

We may also use your Personal Information to improve our Platform, products, and services. This may include using your information to customize your experience with us. We may also use your Personal Information for the security of the Platform and our company, our customers, and other third parties. We may also use your Personal Information to protect against fraud and other malicious activity.

We may also your information for marketing purposes. For example, we may send you information about new features on the Platform, new services we offer, and special offers. When legally permitted, this may also include using your information to serve you ads and to tell you about products or offers available through third parties we think you might find interesting. These might be our own offers, third-party offers, or products we think you might find interesting.

Finally, we may use your information for other purposes, as permitted by law.

5. Sharing Personal Information
We may share your Personal Information in the following circumstances:

  • Within Soleo – We may share your Personal Information within our family of companies.
  • Service Providers– When we hire a service provider to help operate the Platform or our business, we may give access to Personal Information as necessary to perform the service for Soleo. This may include service providers that operate our website, send our communications, or run our promotions.
  • Business Partners – Soleo may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners may use your information to, among other things, send you information or contact you about their services and products.
  • Third Parties for Marketing Purposes – We may share your Personal Information with third parties for their marketing purposes. This may include third parties whose services we believe you may be interested in or who are interested in providing you with services. These third parties may share your information with others and may use this information for their own interest-based advertising.
  • Legal Obligation or Protection From Harm – When Soleo has a good faith belief that access, use, preservation or disclosure of the Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Soleo, its users, or the public against harm.
  • Merger or Sale – If and when Soleo is involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required, we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
  • Purposes Described to You – We may share your Personal Information for other purposes, as we describe to you.

6. Cookies and Other Technologies
We collect information about users over time on the Platform by using several common types of cookies and other tracking technologies, including web beacons, pixels, and flash cookies. We also have third parties that collect information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. For more information about cookies, visit http://www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies operate independently of cookies.

To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics. For more information on how Google Analytics processes your information, please see “How Google uses data when you use our partners’ Platforms or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

These cookies may be ones placed by us (first party) or by a third party. These cookies may also be Flash Cookies. To learn how to manage privacy and storage settings for Flash cookies, click here. We may use cookies that are session-based or persistent. Session cookies expire when you close your browser or turn off your device. Persistent cookies remain on your device after you close your browser or turn off the device.

We may use a variety of cookies:

Types of Cookies
Required Required cookies are essential for the Platform to function properly and for you to navigate our Site and use its features, such as accessing secure areas of the Platform and using our services.
Performance These cookies collect information about how you use the Platform, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs.
Functionality Functionality cookies allow the Platform to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Platform after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
Targeting or Advertising From time to time, we may engage third parties to track and analyze the usage and volume of statistical information from individuals who visit the Platform. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Platform. The information provided to third parties does not include Personal Data, but this information may be re¬associated with Personal Data after we receive it.
By way of example, as you visit the Platform, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Platform.
We also contract with third-party advertising networks and similar partners that collect IP addresses and other information on our Platform, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.
Third parties, with whom we partner to provide certain features on the Platform or to display advertising based on your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.


You can control cookies and tracking tools. Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings. Our Platform does not currently respond to these signals. If you choose to block cookies and other trackers, certain features of the Platform may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. These features and options are browser and device-specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding the use of your web browsing activity for interest-based advertising, you may visit the following sites:

On a mobile device, you may also need to adjust your settings to limit ad tracking.

7. Your Choices
You have certain choices about how we use your Personal Information. You can opt out-out of certain marketing. To opt out of marketing communications, please email us at marketing@soleohealth.com or by following the instructions included in the email or text correspondence. Please note that even if you unsubscribe from certain correspondences, we may still need to contact you with important transactional or administrative information, as permitted by law.

If your personally identifiable information changes, Soleo Health will endeavor to provide a way to correct, update and/or remove your previously provided personal data. This can be done by emailing a request to Soleo Health at marketing@soleohealth.com.

8. Children Under the Age of 13
The Platform is meant for adults, and we will not knowingly collect personally identifiable information from any person under the age of 13 without permission from a parent or guardian. The Platform is not designed to attract the attention of persons under the age of 13. If you are a parent or legal guardian and think your child has given us information, you can email us at marketing@soleohealth.com. You can also write to us at the address listed in the “Contact Us” section of this Policy. Please mark your inquiries as “COPPA Inquiry.”

9. California Privacy Rights
Pursuant to California’s Shite the Light statute (Cal. Civ. Code Sec. 1798.83), you can control if we share information with third parties for their marketing purposes. To opt out of us sharing your information with third parties for such promotional purposes, email us at marketing@soleohealth.com or write to us in the “Contact Us” section of this Policy and include “Marketing Opt-Out” in your request.

In addition, pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), California residents have certain other rights concerning their Personal Information. This section describes (1) the categories of Personal Information collected and disclosed by Soleo, subject to California privacy law, (2) your privacy rights under California privacy law, and (3) how to exercise your rights.

When we use the term “Personal Information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

a. Personal Information We Collect
Soleo makes the following disclosures regarding the categories of Personal Information (enumerated in Section 1798.140(o)(1) of the CCPA) that it has collected within the last 12 months:

Category of Personal Information Collected Category of Source from which Personal Information is Collected Purpose of Collection Third Parties to whom Personal Information is Disclosed for a Business Purpose Third Parties to whom Personal Information is Sold or Shared Retention Period
Identifiers Yes Directly from you; cookies and other tracking technologies See the section above titled “How We Use Personal Information” Service Providers Third-party advertisers 6 years from the date of creation or the date last effective, whichever is longer
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Yes Directly from you See the section above titled “How We Use Personal Information” Service Providers We do not sell or share this category of Personal Information 6 years from the date of creation or the date last effective, whichever is longer
Protected classification characteristics under California or federal law No N/A N/A N/A N/A N/A
Commercial information No N/A N/A N/A N/A N/A
Biometric information No N/A N/A N/A N/A N/A
Internet or other similar network activity Yes Cookies and other tracking technologies N/A Service Providers Third-party advertisers Varies depending on the type of cookie collecting this category of Personal Information, but no more than 6 years from the date of creation or date last effective, whichever is longer
Geolocation data Yes Cookies and other tracking technologies See the section above titled “How We Use Personal Information” Service Providers We do not sell or share this category of Personal Information 6 years from the date of creation or the date last effective, whichever is longer
Sensory data No N/A N/A N/A N/A N/A
Professional or employment-related information Yes Directly from you See the section above titled “How We Use Personal Information” Service Providers We do not sell or share this category of Personal Information 6 years from termination of employment or last entry, whichever is later
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) No N/A N/A N/A N/A N/A
Inferences drawn from other personal information No N/A N/A N/A N/A N/A
Sensitive Personal Information Yes Directly from you See the section above titled “How We Use Personal Information” Service Providers We do not sell or share this category of Personal Information 6 years from the date of creation or the date last effective, whichever is longer


b. Your Privacy Rights
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories of privacy rights with respect to their Personal Information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

Privacy Right Description
Notice You have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access You have the right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request the categories of Personal Information which were disclosed for business purposes and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Erasure You can request to have your Personal Information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Correction You have the right to request that we correct any incorrect Personal Information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your Personal Information on our behalf to correct) your Personal Information from our records unless an exception applies. We may deny your correction request if (a) we believe the Personal Information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
To Opt Out of Sales or Sharing of Personal Information You can request to opt out of us selling or sharing your information Personal Information. To exercise this right, please click here and follow the instructions to submit your request. As noted above, in the past 12 months, we may have enabled advertisers to collect certain information from the Platform, which the advertisers may use to improve their interest-based advertising networks. Regardless of whether this is considered a “sale” or “share” under the CCPA, you may adjust your browser settings to opt out of this type of information collection, as described in Section 6 above. Except as described above, Soleo does not sell or share your Personal Information. Soleo only uses your Personal Information to conduct our normal business operations as outlined above.


c. How to Exercise Your Rights
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to marketing@soleohealth.com or call us toll-free at: 833.234.1010. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

  • Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
  • Help Us Verify Your Identity: Provide us with enough information to verify your identity. For example, provide us (at a minimum) your full name, address, and phone number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
  • Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).

Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.

d. How We Respond to Your Requests
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine-readable, readily useable format that allows you to freely transmit this information without hindrance.

Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests if determined by us to be unfounded or excessive (e.g., repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.

10. Storage, Security and Retention of Information
Soleo has taken reasonable steps to protect the information users share with us, including, but not limited to, the setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information. We will retain your Personal Information in compliance with the uses described in this Policy, as well as to comply with our legal, financial reporting, or compliance obligations.

We store information only inside the United States. If you live outside of the United States, be advised that we may transfer and store your information in the United States. US law may not provide the same protections as the laws in your country. By providing us with your Personal Information, you agree to the processing of it in the United States as permitted by US law.

11. Links to Third Parties and their Sites
Our Platform may include third-party content and links to third-party websites and services that collect Personal Information. We do not control these third parties, and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use the information you provide to them. Please read the third parties’ privacy policies carefully.

12. Contacting Soleo Health
If you have any questions about this Policy or the privacy practices of Soleo, please email us at marketing@soleohealth.com or write to us at:

Soleo Health
Attn: Communications Department
2801 Network Blvd., Ste. 505
Frisco, TX 75034

13. Updates
Please note that this policy may be amended from time to time. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to the Platform, so please check our site periodically for updates. You can see when this Policy was last updated by reviewing the “Last Updated” legend at the top of this page. We will provide notice of material changes by updating the Policy here and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.