Privacy Policy

SONIFI Health, Inc. (“SONIFI”) – Effective April 2023

Protecting your information is important to us. The following guidelines set forth our general privacy practices and principles that apply to information we collect through our various websites, including sonifi.com, sonifihealth.com, and sonifisolutions.com, information portals, and related applications, including the StayConnect® App (collectively the “Sites”), which are owned or operated by or on behalf of SONIFI Solutions, Inc., or companies related by common ownership or control (collectively, “we,” “us,” or “our”). We use this privacy notice to clearly disclose to you our privacy practices in a manner that is easy to understand. If there is something you do not understand about our privacy practices, please feel free to contact us at privacy@sonifi.com.

This privacy notice does not apply to products or services provided, or information obtained, other than through the Sites. We do not intentionally collect information from persons under the age of 13, so please do not use any of the Sites if you are under the age of 13. We may change this notice from time to time so please check back often. If we significantly change our collection, use, or disclosure practices, we will try to send you a notice via email if you have provided us with an email address. Please keep in mind that some of the services mentioned specifically in this notice may not be available on the site at this time. This Privacy Notice is effective as of April 1, 2023.

Our Sites are used to provide information about the technology we offer, and the hospitality and healthcare products and services we provide.

If you are applying for a job with SONIFI or are completing our employee on-boarding processes, your use of the Sites is governed by our HR privacy policy. Any medical or health information collected is governed by the Health Insurance Portability and Accountability Act (“HIPAA”); to the extent we process such information it would be subject to a Business Associate Agreement entered into with the subject Covered Entity. In certain instances, we may be processing information in our role as a service provider, such information would be subject to the privacy policy of the relevant Controller or Business.

What information do we collect from you?

In brief: As part of providing products and services to you, we may collect information, including personal information about you.

As part of providing products and services to you, we may collect information, including personal information, about you or your business. Personal information is data that can be used to identify you. The information includes but is not limited to:

  • Name
  • Email address
  • Mailing address
  • Phone number
  • Birth date
  • Gender
  • Zip code
  • Company name
  • Job title
  • Other information you disclose when you ask us a question about our Sites or our products and services.
  • Technical information about your use of our site including IP address, device identifier, and viewing information

How do we collect information from you?

In brief: We collect information from you directly when you enter it into a form on our Sites. We collect information from you indirectly and automatically through the use of cookies, web beacons and log files.

Direct Collection

We collect much of the information listed above directly from you when you submit it on our Sites. This includes information you share on the Contact Us page of our Sites.

Information We Receive from Others

We offer product and services to enterprise customers such as hotels, healthcare providers, and other establishments. If you engage with SONIFI’s products and services offered by such SONIFI customers, we may receive and process information related to your use of those services, and in some cases information about the device used to do so. We collect and track only the necessary information regarding the transaction, the facility information, the service provided, etc. In most instances, such information is associated with a temporary anonymized identification code used only during your stay at that facility. We may also generate reports for such third-party facilities that allow such transactional data to be associated with other personal information controlled by the facility. We may also collect and process personal information from trusted partners, including business partners who provide us with information about users and potential users of our services.

Indirect Collection – Cookies and Other Technology

As part of offering and providing customizable and personalized services, we use cookies and other online tracking technologies to

store and sometimes track information about you. In some states and countries, including countries in the European Economic Area and the United Kingdom, this information may be considered personal information under applicable data protection laws. We may use these technologies to:

  • Provide you with personalized content based on your use of our Sites;
  • Enable you to more easily use our Sites by remembering and using contact information, purchasing information, and registration information;
  • Evaluate, monitor and analyze the use of our Sites and traffic patterns to help improve our Sites and services; and
  • Assist us with ad reporting functions such as learning which ads are bringing users to our Sites.

The types of technologies we use include:

Cookies. A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive. Cookies enable us to identify your browser as a unique user. Cookies may involve the transmission of information from us to you and from you to us. Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy statement. Some cookies are “persistent cookies.” They are used by us each time you access our Sites. Other cookies are called “session cookies.” Session cookies are used only during a specific browsing session. We may use a session cookie, for example, to remember that you have already navigated through a particular menu, or that you have entered in age information for a portion of a site that is restricted by age. We may also use “analytics cookies” that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our Sites before, what you have previously viewed or clicked on, and how you found us. This information is provided anonymously for statistical analysis only. Analytics cookies are usually persistent cookies.

Web Beacons. We also employ a software technology called a clear GIF (Graphics Interchange Format), also known as a pixel tag or Web beacon. A clear GIF is a line of code that we place on our Sites or in e-mails which allows us to analyze our advertising and the general usage patterns of visitors to our Sites. These help us better manage content on our site by informing us what content or promotions are effective. Unless you consent, we do not collect personally identifiable information from you through the use of web beacons. You may not disable Web beacons.

Log Files. Like most standard website servers, we use log files. Log files track Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the site, prevent fraud, track website navigation in the aggregate, and gather broad demographic information for aggregate use.

Social Networking. The Sites may permit you to use a third party social networking platform such as Facebook and LinkedIn. These plug-ins allow you to follow us on those services. When you use social networking platforms and plugins, you share your information with them and their privacy notice applies to their disclosure of such information. In addition, they may be able to collect information about you, including your activity or may notify your connections on the social networking platform about your use of our Sites. Such services may allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising. Please note that their own privacy polices apply and we encourage you to read them. We may add new social networking plugins and buttons to our Sites from time to time.

Google, Inc., may utilize the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google, Inc. services. Google, Inc. may also use the data collected to contextualize and personalize the ads of its own advertising network to serve ads to you based on your visit to our Sites and other sites on the Internet. You may view Google’s privacy policy here: https://policies.google.com/privacy?hl=en, with more information located here: https://www.google.com/policies/privacy/partners/ (including information regarding how to control how information is shared through your Ads Settings) and here: https://support.google.com/analytics/answer/6004245?hl=en.

Facebook similarly provides more information regarding the information it collects and how it is used in relation to advertising here: https://www.facebook.com/policy.php.

What choices do you have about the collection of information about you?

In brief: You can always choose not to submit information. You can disable cookies in your browser. You can choose not to use social networking plug-ins. You can opt-out of our marketing related emails.

Direct Collection. If you do not want to share your information, you can choose not to participate in a particular service or activity.

Cookies. You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent. You may lose some features or functionality when you disable cookies. Remember, also, that disabling cookies is browser specific. If you log on using Google Chrome, you must also disable cookies in Safari if you use that browser at a different time.

Web Beacons. It is not possible to disable Web beacons.

Log Files. It is not possible to disable log files.

Social Networking. If you do not want to share your information, you can choose not to use social networking plug-ins.

Marketing Emails. To ensure that you will not receive recurring marketing or other information from us unless you choose to, we will provide you with simple instructions on each marketing email from us for you to let us know that you have chosen to stop receiving such emails from us.

Do Not Track. Do Not Track (DNT) is a privacy preference that users can set in their web browsers. While the United States Federal Trade Commission has endorsed DNT, our Sites does not currently support DNT codes.

Google Analytics. You may opt-out of Google Analytics collection by downloading the browser plugin “Google Analytics Opt-out Browser Add-on” here.

Facebook. You may opt-out of Facebook’s collection and sharing of information here.

How do we use your information?

In brief: Our main goal in collecting information is to improve the site and provide you with the best possible experience on the site. For example, by using the information we collect, we can provide you with an easy to use and readily available forum to ask questions about our products and services.

We may use your personal information to:

  • Answer questions you may have about our products and services
  • Notify you of other products or services available from us and our affiliates
  • Personalize online content so that is applies to you and your interests
  • Provide you with advertising targeted on your interests
  • Make our products, services, and Sites better
  • Compile, analyze and do research on our users’ demographics and behavior
  • Detect, investigate and prevent activities that may violate our policies or be illegal

We use, and share location data only to provide and improve our service.

Who is collecting your information?

In brief: We collect your personal information and may use third party service providers to assist with that collection.

When you are on our site and are asked for personal information, you are sharing that information with us and our affiliates and service providers. Although we generally operate the Sites and collect the information, we may engage third party service providers to assist us in that collection.

Other websites to which we link may collect personally identifiable information about you when you visit those sites. The information practices of other websites linked to our websites are not covered by this privacy notice.

With whom do we share your information?

In brief: We share your information with companies who assist us in providing services, when we need to protect our Sites or information and when we sell our businesses. We do not sell your personal information to third parties.

We will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. These are some of the ways that your information may be disclosed:

Service Providers

We occasionally hire other companies to provide limited services on our behalf, including packaging, delivering, or mailing, website development and operation, answering customer questions about products or services, sending postal mail or email, analyzing website use, providing investor information and processing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other reason.

Customers

We may disclose data with another company, such as a hotel or hospital, that has contracted with us to receive the services that we provide. We will only provide those companies the information they need to deliver the services at those facilities. In most instances they are the data controller for whom we are processing such information.

Business Partners

We may disclose data with another company that operate as our business partner. We will only provide those companies the information they need to deliver the services and that are contractually prohibited from using that information for any other reason. We may also disclose information to our corporate affiliates.

Data in the Aggregate

We may disclose “anonymized” aggregated data and user statistics to prospective partners and other third parties. Anonymized data is data that does not identify an individual person.

Other

We also may disclose your information in special cases. For example, when we believe that we must disclose information to identify, contact or bring legal action against someone who may be violating our Terms of Service, or may be causing injury to or interference with our rights or property, other website users or customers and their information, or anyone else who may be harmed by such activities. We may disclose, access or monitor your personal information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services and our information security.

As we continue to develop our business, we may buy or sell businesses or assets. In such transactions, confidential customer information generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of our businesses, customer and site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction. In such case, the transferred information may become subject to a different privacy notice.

How can I control my personal information?

In brief: We offer our customers choices for the collection, use and sharing of personal information.

You may contact us at privacy@sonifi.comif you wish to view, edit, or delete your personal information from our database, and we will use commercially reasonable efforts to accommodate your request.

If you believe that any inaccurate or inappropriate information has been obtained or provided to others through your use of our Sites, you should contact a representative at privacy@sonifi.com.

How do we protect your information?

In brief: We use commercially reasonable efforts to protect your information. The Sites does not use encryption except where noted.

Financial Information

We do not currently collect personal financial information on the Sites, other than transaction data related to the services we provide.

Other Information

Because information sent through the Internet travels from computer to computer throughout the world, when you give us information, that information may be sent electronically to servers outside of the country where you originally entered the information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Except as specifically stated, this site does not use security encryption measures. Information that you disclose by use of this site (as with any site that is non-secure), by posting a message or using e-mail, potentially could be collected and used by others. This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems.

How long do we keep your personal information?

In brief: We keep your information for a time that is reasonable based on the appropriate circumstances.

The length of time we retain personal information will be determined based upon criteria such as: the length of time your personal information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators; or the type of contract we have with you, the existence of your consent, and our legitimate interest or business need in keeping such information (for example, to provide you with a service you have requested or to comply with applicable legal, tax, compliance, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your California Privacy Rights.

In brief: California residents are entitled to additional protections under California Law including the right to request information about third parties to whom we disclose information for marketing purposes.

If you are a California Resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA).

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@sonifi.com.

Make sure to state that you are a California Resident.

Scope of Notice

This notice applies to personal information we collect about California residents both online and offline. It applies to California residents who are users of our Sites; our customers; individuals inquiring about our products; and all other California residents from whom we collect personal information.

As defined in the CCPA, personal information includes any information that identifies, relates to, or could reasonably be linked to a California resident or household. It includes, but is not limited to: identifiers, characteristics of protected classes, commercial information, biometrics, internet or electronic information, geolocation data, audio/visual or similar information, employment and educational information, and inferences drawn from any identifiable information. Personal information does not include publicly available information from a public government record.

This notice does not apply to information that is exempt from CCPA disclosure requirements. This disclosure also does not apply to individuals who are not California residents, any personal information exempted under Cal. Civ. Code Section 1798.145, or any other personal information not contemplated in the CCPA.

Rights of California Residents Under the CCPA

This Privacy Notice for California Residents supplements the information contained above in our general privacy policy and applies solely to all visitors, users, households and others who reside in the State of California.

Your Rights

The California Consumer Privacy Act (“CCPA”) grants State of California residents the following rights, to:

  • Know what personal information is being collected about them;
  • Know whether their personal information is sold or disclosed and to whom;
  • Say no to the sale or sharing of their personal information;
  • Access their personal information;
  • Have their personal information corrected if inaccurate;
  • Have their personal information deleted (subject to certain exceptions);
  • Have the right to equal service and price, even if they exercise their privacy rights under this law; and
  • Limit the use of their sensitive personal information.

We will also be modifying this policy to comply with the new regulations related to the California Privacy Rights Act (“CPRA”) so check back for updates.

Categories of Information Collected

We collect, use and disclose personal information for various business purposes described above. While collection practices vary depending on the business purpose, we collect and have collected the following

categories of information over the past 12 months, as defined in the CCPA:

Identifiers

  • First and last name
  • Email address
  • Mailing address
  • Phone number
  • Company name
  • Title
  • Internet Protocol (IP) Address

Personal Information Listed in the California Customer Records Statute

  • From customers and users of our services, we collect no Personal Information in this category other than the identifiers listed above

Characteristics of Protected Classifications

  • From customers and users of our service, we do not collect Personal Information in this category

Commercial Information

  • Transaction information
  • Information about your in-room orders

Biometric Information

  • From customers and users of our service, we do not collect Personal Information in this category

Internet or Other Electronic Network Activity Information

  • Cookies
  • Domain name
  • Browser type
  • Operating system
  • App usage
  • Device identifiers
  • MAC address
  • Usage data

Geolocation Data

  • Information that tells us from where you access our Sites

Sensory Data

  • From customers and users of our service, we do not collect Personal Information in this category

Professional or Employment-Related Information

  • From customers and users of our service, we do not collect Personal Information in this category

Non-public Education Information

  • From customers and users of our service, we do not collect Personal Information in this category

Inferences Drawn from Other Personal Information

  • We do not collect this information.

Exceptions to our Disclosure Limitations

We also may disclose your information in special cases related to our legal obligations and to protect from the misuse of our Sites. We may share your personal information in regard to legal proceedings if stemming from a violation of our Terms of Service or causing injury to us, our property, our Sites, our clients or others. We may disclose visitor information when subpoenaed, if ordered or otherwise required by a court of law, arbitrator, or other similar proceeding, for government investigations, with government agencies if required by law, and when we otherwise believe in good faith that any applicable law requires it.

How We Retain and Store Your Personal Information

We retain your personal information for as long as necessary to fulfill the purpose(s) for which we collected it and to comply with applicable laws. We use reasonable security procedures and practices to protect

your information while in storage for each category of personal information we collect.

Requests to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling/sharing that personal information.
  • The categories of third parties with whom we sell or share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • Sales and sharing, identifying the personal information categories that each category of recipient purchased or received; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained and the categories of persons to whom it was disclosed for a business purpose.

Requests to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you. This includes fulfilling a warranty request.
  2. Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
  3. Debug online services to identify and repair errors that impair existing intended functionality.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  6. Comply with a legal obligation.
  7. Make other internal uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Your Personal Information or Sharing of Personal Information for Targeted Advertising. California residents have the right to opt-out of having your personal information sold or your personal information shared for Targeted Advertising. While we do not sell personal information in the traditional sense of selling personal information in exchange for money, certain or our activities (such as sharing online identifiers with third parties) may be considered a sale under California or other law. We do not sell personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age. To request that your personal information not be sold or shared for Targeted Advertising, please see below. Note that Targeted Advertising does not include advertising from or on behalf of us based on activities conducted on our own Sites.

Right to Opt-Out of Profiling. Certain consumers have the right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer. Please see below to submit to opt-out of such profiling.

Right to Obtain Copy of Your Personal Information. Certain consumers have the right to obtain a copy of the personal information in a portable and readily usable format. Please see below to submit a request to a copy of your personal information.

Right to Correct. You may submit a request to correct any inaccuracies in your personal information. To do so, please below.

Right to Restriction. You may submit a request to limit the use and disclosure of your sensitive personal information. Sensitive information includes information like your social security number, sexual orientation, religious beliefs, private health matters, union membership and other such information depending on the applicable privacy law. To do so, please below

How to Submit a Request to Know, Delete, or to Request a Copy

To request this information please submit a verifiable consumer request to us by either:

  • Calling us at 1-888-414-8463
  • Emailing us at privacy@sonifi.com
  • Sending a written request to: Privacy Officer, SONIFI Solutions, Inc., 3900 West Innovation Street, Sioux Falls SD 57107

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, email us at privacy@sonifi.com and we will provide you with a form to make a designated agent request. Please do not send us any sensitive personal information using email. Email transmissions are not secure.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will try to respond to your request within forty-five (45) days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt unless required otherwise under the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We do not process privacy requests sent to us using third-party services. This is because such services often request that we click on hyperlinks which we will not do for data security reasons. These services are also susceptible to spoofing and other phishing attacks. One of our highest priorities is to treat your information safely and securely. If you live in a state that permits you to make a privacy request using a third-party agent, please have them contact us using the information above and we will take steps to identify them and ensure that they are your agent.

How to Submit an Opt-Out Request/ Limit the Use or Disclosure of Sensitive Personal Information

We do not sell your personal information to third parties for money or other consideration. However, we do share your personal information as described herein.

If you would like to submit an opt-out request or a request to limit the use or disclosure of your personal information, please use these “Do Not Sell or Share My Personal Information” and the “Limit the Use of My Sensitive Personal Information” links.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Your Nevada Privacy Rights

In brief: Nevada privacy law allows you to opt-out of the sharing of personal information with third parties.

Opt-Out Requests

Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information should we change our practices in the future, you must send a request by e-mail at privacy@sonifi.com. Make sure to state that you are a Nevada resident.

Your GDPR Rights

In brief: If you are a European Union resident, the General Data Protection Regulation (“GDPR”) may provide you with additional rights regarding our use of your personal information (“GDPR Rights”).

If you are a European Union resident, the General Data Protection Regulation (“GDPR”) may provide you with additional rights regarding our use of your personal information (“GDPR Rights”). This section describes additional information concerning GDPR Rights.

When you stay at a hotel property or are at healthcare facility or other location that uses SONIFI technology, we are acting as a “Processor” to such property or facility which is a “Controller” under the GDPR. In that case, your Personal Information is controlled by the Controller and if you wish to exercise your GDPR Rights, you need to make a request to the Controller under their privacy policy. As a Processor, we will assist the Controller in complying with your request.

GDPR Principles: SONIFI is committed to following the GDPR principles for personal information processing.

  • Lawfulness, fairness, and transparency. SONIFI will only process personal information in such a manner as would reasonably be expected, and will be transparent in its processing of personal information.
  • Purpose limitation: SONIFI will process personal information only for the specific purpose it was collected.
  • Data minimization: SONIFI does not collect or process more personal information than reasonably required.
  • Accuracy: SONIFI takes reasonable steps to confirm that any personal information held is both adequate and accurate.
  • Storage limitation: SONIFI does not store personal information for longer than necessary or required.
  • Integrity and confidentiality: SONIFI takes reasonable steps to protect the integrity, security and confidentiality of personal information.

Legal Basis for Processing: SONIFI will only process personal information when it has a legal basis for doing so. These may include:

  • Consent: the data subject has consented to the use of the personal information.
  • Contract: processing of the personal information is necessary to fulfill a contractual obligation.
  • Legal obligation: A legal, regulatory, or judicial process requires processing of such personal information.
  • Vital interests: Someone’s life, health or security depends on the processing of such personal information
  • Public task: The processing of such personal information is necessary to carry out a task in the public interest
  • Legitimate interests: processing the personal information serves a legitimate interest, as determined by an appropriate assessment, such as the improvement of our services or operations.

Processing of Personal Information: SONIFI processes personal information in the United States of America. Personal information transmitted from other countries is subject to standard contractual clauses concerning the transfer of such information.

Exercising GDPR Rights: To exercise GDPR Rights concerning the accessing, managing, rectifying, erasing, etc., of personal information, or to contact SONIFI’s Privacy Officer, please follow the same process as for submitting a verifiable request under the CCPA, as described above.

Who do you contact with questions or concerns about our Privacy Notice?

If you need further assistance, please send an e-mail with your questions or comments to privacy@sonifi.com or write us at:

Privacy Officer
SONIFI Solutions, Inc.
3900 West Innovation Street
Sioux Falls, SD 57107