SCOPE
Somahlution, LLC (“Somahlution”, “We”, “Our”, “Us”) respects individuals’ privacy, and strives to collect, use and disclose personal data in a manner consistent with the laws of the countries in which it does business. This Privacy Policy (the “Policy”) sets forth the privacy principles Somahlution follows with respect to personal data it receives from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States you provide on our Web site www.somahlution.com and offline.

SCOPE
This Privacy Policy (the “Policy”) applies to all Personal Data received by Somahlution in the United States from EEA (the European Economic Area), either directly from individuals or from its affiliates and in any format including electronic, paper or verbal.

DEFINITIONS
For the purposes of the policy, the following definitions shall apply:

“Agent”
 means any third party that processes, collects or uses Personal Data under the instructions of, and solely for, Somahlution or to which Somahlution discloses Personal Data for use on Somahlution’s behalf.

“Personal Data” means any information or set of information that (1) is transferred from the EEA to the United States, (2) recorded in any form and (3) identifies or could be used by or on behalf of Somahlution to identify any individual. Personal Data does not include encoded or anonymized information, aggregated information or publicly available information that has not been combined with non-public Personal Data.

“Sensitive Personal Data”
 means Personal information that: (a) reveals race; ethnic origin; political opinions, religious, ideological or philosophical beliefs; or trade union membership, views or activities; (b) concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings or (c) is received from a third party where that third party identifies and treats the information as sensitive personal data pursuant to the EU Data Directive

INFORMATION COLLECTED
On the Somahlution Sites, we only collect your personal data (such as your name, address, telephone number or e-mail address) when you choose to submit it to us, and we only use it for those purposes that you have approved. For example, you may choose to register to receive additional product information or information about a disease state that interests you, in which case your personal data will be used only for that purpose. In some cases, we remove personal identifiers from data and maintain it in aggregate form. We may combine this data with other information to produce anonymous, aggregated statistical information helpful to us in improving our products and services

NOTICE
Somahlution will inform individuals about the types of personal data it collects about them, the purposes for which we collect and use such data, how to contact us, the types of non- agent third parties with whom we may share such data, and any ways that individuals may limit the use and sharing of such data. Except as provided by law or to protect the health or safety of individuals, this notice will be provided in clear and conspicuous language when individuals are first asked to provide personal data or as soon thereafter as is practicable, and before Somahlution uses or discloses the information for a purpose other than that for which it was originally collected

CHOICE

Somahlution, LLC, will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a non-agent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual. The “opt out” will be available at the time of collection and at any point thereafter. The option will be exercised through the use of an “opt out” program. The option to opt out will be available through the program that is used to collect personal data. Additionally any individual can request to opt out by sending an e-mail to optout@somahlution.com

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you.  Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at unsubscribe@somahlution.com

Somahlution, LLC, will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual.

TRANSFER TO AGENTS
Somahlution will obtain assurances from its Agents that they will safeguard Personal Data in a manner consistent with this Policy. Examples of appropriate assurances that may be provided by Agents include: (1) the Agent’s execution of the Model Standard Clauses as set forth by the EU (2) being subject to the EU Data Protection Directive (EU Directive 95/46/EC), or another law providing an adequate level of privacy protection. Where Somahlution has knowledge that an Agent is using or disclosing Personal Data in a manner contrary to this Policy, Somahlution will take reasonable steps to prevent or stop the use or disclosure.

ONWARD TRANSFER

Somahlution, LLC, and its affiliates will only transfer personal data to a non-agent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

SECURITY
We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. Somahlution will take reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration or destruction. As necessary, Somahlution will take additional precautions regarding the security of Sensitive Personal Data. While Somahlution strives to secure Personal Data, even reasonable security measures do not guarantee the security of any information, and Somahlution cannot guarantee that the Personal Data it seeks to protect will be protected in all circumstances, including those beyond its reasonable control. Records containing Personal Data are considered Somahlution property and should be afforded confidential treatment at all times, regardless of whether these records are in electronic or paper form. If you have any questions about security on our Web site, you can contact us at IT@somahlution.com

ACCESS AND CORRECTION
Ipon request, Somahlution will grant individuals reasonable access to personal Data that it holds about them. In addition, Somahlution will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Somahlution may limit or deny access to Personal Data as permitted by the EU regulations and policies.. For example, Somahlution may limit an individual’s access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where the legitimate rights of persons other than the individual would be violated.

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove or deactivate it by making the change on our member information page or by emailing our Customer Support at safeharbor@somahlution.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at safeharbor@somahlution.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

DATA INTEGRITY
Somahlution will use personal data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Somahlution will take reasonable steps to ensure that personal data is relevant to its intended use, accurate, complete, and current and reliable for intended use.

ENFORCEMENT
Somahlution, LLC, has put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us at the address below, and we will do our best to resolve them. Any employee that Somahlution determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

INFORMATION SHARING
We will share your personal data with third parties only in the ways that are described in this privacy statement. We do not sell your personal data to third parties. If you do not want us to share your personal information with these companies, contact us here

We may provide your personal data to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal data only as necessary to provide these services to us. In certain situations, Somahlution, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal data:

(a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, and

(b) to the extent expressly permitted by an applicable law, rule or regulation.

(c) if Somahlution is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web Site of any change in ownership or uses of your information, as well as any choices you may have regarding your personal data.

(d) to any other third party with your prior consent to do so.

AUTOMATICALLY COLLECTED INFORMATION
We automatically collect certain types of information whenever you interact with us on the Somahlution Sites and in some e-mails we may send each other. Automatic technologies we use may include, for example, cookies and web beacons.

We Somahlution, LLC and our partners use technologies such as cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.

Analytics / Log Files: As is true of most web sites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We do not link this automatically-collected data to other information we collect about you.

LINKS TO 3RD PARTY SITES
Our Site includes links to other Web sites whose privacy practices may differ from those of Somahlution. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

SOCIAL MEDIA WIDGETS
Our Web site includes Social Media Features, such as the LinkedIn button .  These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

HOW TO CONTACT US
Please contact us with any questions about this Privacy Policy or any of our privacy practices. All individuals covered by this Policy should contact us at

Somahlution, LLC, Information Technology Officer
225 Chimney Corner Lane, Suite 2002, Jupiter, FL
Phone: 561-935-9955
Fax: 561-529-4249
safeharbor@somahlution.com

CHANGES TO THIS POLICY
We may update this Privacy Policy to reflect changes to our information practices. When we do, we will also revise the “last updated” date at the bottom of this Policy. For material changes to this Policy, we will notify individuals by placing a notice on the following Web site: [http://somahlution.com/privacy-policy] or by sending you an email (sent to the e-mail address specified on your account) prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

EFFECTIVE DATE 
This Policy is effective as of 17 November 2016.