LAST UPDATED: [12/20/2023]

Rolland Canada Holdings, Inc., a corporation incorporated under the laws of Québec, Rolland USA Holdings, Inc., a Delaware corporation, and FRF Holdings, Inc., a Delaware corporation, Rolland Enterprises, Inc., a corporation incorporated under the laws of Québec, The Hanna Group Ltd., a corporation incorporated under the laws of Ontario, and their affiliates (collectively, d/b/a Sustana Fiber, hereinafter “Sustana” or “us” or “we” or “our”) are committed to protecting your privacy. This Privacy Policy describes the types of personal information that Sustana may collect from you or that you may provide when you visit the website http://www.sustanasolutions.com  (the “Website”) as well as our practices for using, maintaining, protecting, and disclosing that personal information.  Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

This Privacy Policy does not apply to employee or applicant data collection. Please see our California Job Applicant Privacy for more information.

Personal Information We Collect About You

We collect the following types of personal information about you through our Website (e.g., when you submit a “contact us” request form): 

• Contact information, including your name, postal address, phone number, and email address.
• Identifiers, such as IP address and other similar digital identifiers.

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To verify your identity.
• To improve our services to you, including to run analytics, assess the quality of our services, and other related internal business purposes.
• To communicate with you to personalize your relationship with us, improve our understanding of your needs, and to respond to your inquiries.
• To respond to legal actions and/or law enforcement requests and otherwise comply with requests and legal obligations as required by applicable law, court order, or governmental regulations.

Where personal information is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent, to our processing of your personal information by contacting us as described in the “Contact Information” section below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain parts of our Services.

How We Share Your Personal Information

We share or disclose personal information about you to:

• To our affiliates for proper business purposes in connection with the provision of services to you;
• To non-affiliated third parties and service providers (such as attorneys, accountants, tax preparers, service providers, agents and administrators) as necessary for us to provide agreed-upon services and products to you consistent with applicable law. Any non-affiliated third parties are not allowed to use your personal information for their own purposes and are contractually or legally obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific services we have requested;
• To you, and persons we believe to be your authorized agents or representatives;
• In relation to a corporate transaction, such as if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, including negotiation and diligence of such transactions; and
• To regulators and courts if compelled to do so, in order to satisfy our regulatory and other obligations to such entities in accordance with applicable law.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sustana, our customers, or others.

Some of our service providers may be located outside of Canada or the United States, including in the United States. While outside of Canada or the United States, personal information may be subject to applicable data protection laws, which may permit government and national security agencies to access your information in certain circumstances. For more information about our service providers, please contact dataprivacy@sustanasolutions.com

We do not and will not sell your personal information to anyone. Nor do we share your personal information to third parties for their own marketing purposes.

How We Protect Your Personal Information

We protect personal information using safeguards that are appropriate to the sensitivity of the information. These safeguards may include measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. We limit access to personal information to our employees and service providers who require access in connection with their role or function. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information. Despite these measures, since no system or security measure is completely secure, it is possible that personal information may be lost, stolen or accessed without authorization.

Personal information is maintained on our servers or those of our service providers and is retained as long as necessary for the fulfillment of the purposes for which it was collected, in accordance with prudent business practices on general document retention, or as otherwise required by law.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age, or in Quebec under the age of 14. No one under age 13, or in Quebec under 14, may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13, or in Quebec under 14. If you are under 13, or in Quebec under 14, do not use or provide any information on this Website or through any of its features. If we learn we have collected or received personal information from a child under 13, or in Quebec under 14, without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, or in Quebec under 14, please contact us at dataprivacy@sustanasolutions.com

Cookies and Data Collection Technologies

We may use cookies and other data collection technologies like web beacons to improve our services to you. A cookie is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (when it expires), and a randomly generated unique identifier. A cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using the services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic.

To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Most commercial browsers allow you to disable cookies. Some web browsers allow you to control or reject cookies or alert you when a cookie is placed on your computer or device. These browser settings are typically found in the “options,” “tools,” or “preferences” menu of your browser. You can also consult your browser’s “help” menu for more instructions on how to control your cookie settings.

We also use Google Analytics (website analytics tool) and other third parties’ tagging and analytic tools to provide usage statistics and support your access to and use of our Website. Google Analytics and other third parties use cookies to collect information, such as the number of visitors to the website, the pages visited, and the length of time on the Website. To learn more about how Google Analytics uses and shares your information and what choices you have, please visit https://www.google.com/policies/privacy/partners/ and https://www.google.com/analytics/terms/us.html.

Other third parties’ tagging and analytic tools that we use provide additional information on their sites. For example: Google Marketing Platform, Google Ads, Listenloop, Hotjar, Vendemore, Edelman Internal Traffic Script, Hubspot, and Linkedin.

Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many websites, including ours, do not recognize or respond to DNT signals.

Third-Party Links

Our Website may contain links to other websites that we do not own or operate. We provide links to third party websites as a convenience to you. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Your Choices

You may unsubscribe from our promotional email communications at any time by using the unsubscribe feature included in those messages. Please note that if you unsubscribe from our promotional email communications you may still receive transactional or business-related communications from us.

Notice to Canadian Residents

If you are a resident of Canada, your personal information is collected by Rolland Enterprises, Inc.

You may request access to or correction of your personal information in our custody or control, by writing to us as described below. You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides eligible California residents with certain rights regarding your personal information as described below:

(i) Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide certain information to you about our collection and use of your personal information over the past twelve (12) months. Specifically, you have the right to request disclosure of the categories of personal information and specific pieces of personal information we have collected about you over the last 12 months. Upon the submission of a verifiable consumer request (see Exercising your Rights to Know), we will disclose to you:

The categories of personal information we collected about you.

The categories of sources from which personal information was collected.

Our business or commercial purpose for collecting or selling personal information.

The categories of third parties with whom we shared personal information.

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and

disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We will also provide the specific pieces of personal information we collected about you, subject to certain exceptions under applicable law, if you also request access to such information.

(ii) Right to Delete

If you are a California resident, you also have the right to request that we delete any of your personal information that we collected or maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will conduct a reasonable search of our records in order to locate any personal information we have collected about you that is eligible for deletion, and delete such personal information. To the extent we have shared any personal information collected about you with service providers that is eligible for deletion, we will direct those service providers to delete that personal information as well. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Following a deletion request, any personal information about you that was not deleted from our systems will only be used for the purposes provided for by the applicable exceptions. Thus, all personal information about you that is not subject to a deletion exception will either be (1) permanently deleted on our existing systems (with the exception of archived or back-up systems maintained for emergency disaster recovery and business continuity purposes); (2) de-identified; or (3) aggregated so as to not be personal to you.

(iii) Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Emailing us at dataprivacy@sustanasolutions.com

Calling us at 920-339-9880

Only you, your parent or guardian (with your permission), the person to whom you have given power of attorney, or an otherwise authorized agent registered with the California Secretary of State, may make a verifiable consumer request related to your personal information. However, you may make a verifiable consumer request on behalf of your minor child. You can designate an authorized agent to submit a verifiable consumer request on your behalf by having the agent submit a request through the online request portal. Additionally, you may only make a verifiable consumer request for access twice within a 12-month period.

Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

(iv) Response Timing and Format

We will confirm receipt of your request within ten (10) business days. We will make our best effort to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests for specific pieces of information that we have collected about you will be sent in a portable, readily useable format that you may transmit to another entity without hindrance.

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.

(v) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

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.

(vi) Your Rights Under “Shine the Light”

In addition to your rights under the CCPA, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to: dataprivacy@sustanasolutions.com.

Notice to Residents of Nevada

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information, including your name and mailing address, to third parties. As of the date of this Privacy Policy, Sustana does not sell any personal information to any third party.  If that were to change in the future, we will update this privacy policy.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

If you have any questions about this Privacy Policy or about our privacy practices, please contact our Privacy Officer at dataprivacy@sustanasolutions.com because your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.