Privacy Policy for OneSolution

Privacy Policy

Scope of This Privacy Policy

This Privacy Policy describes how Forward Solutions and its affiliates (Avision, Curate, C3 Team, ElectroRep, Electris360, Fields Electrical Sales, OneSolution, PJ Boren, RB Sales, RelyPak, StruXur, Xpand Demand) collect, use, disclose, and protect personal information in connection with its business operations and services.

Individuals Covered

This Privacy Policy applies to the following categories of individuals:

  • Customers – individuals and representatives of organizations that purchase or use our products and services
  • Prospective Customers – individuals who inquire about or evaluate our offerings
  • Website Visitors – individuals who access or interact with our websites, portals, or digital properties
  • Business Contacts – individuals who interact with Forward Solutions in a professional capacity, including vendors, partners, and other third parties.

Employee and applicant data is governed by Forward Solutions’ Employee Privacy Notice, which provides specific details regarding how employee and applicant data is collected, used, and protected. Individuals in these categories should refer to the Employee Privacy Notice or contact Human Resources for additional information.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. We do not offer goods and/or services to individuals residing in the European Economic Area (EEA), therefore we are not subject to the EU General Data Protection Regulation (EU GDPR). For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible for your personal information that we possess or control as a "business" under the CCPA/CPRA.

1. Key Terms.

These are some key terms used in this policy:

We, us, our Forward Solutions, LLC, including its affiliates and divisions: Avision, Curate, C3 Team, ElectroRep, Electris360, Fields Electrical Sales, One Solution, PJ Boren, RB Sales, RelyPak, StruXur, and Xpand Demand (“Forward Solutions”, “We”, or “Us”)
Our data protection officer Paul Dennis
Paul.Dennis@forward-solutions.com
Personal information Any information relating to an identified or identifiable individual.
Sensitive Personal Information Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.
Biometric Information An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

2. Personal Information We Collect About You.

Where Forward Solutions processes personal information on behalf of third parties, it does so as a service provider/processor on behalf of the manufacturers and suppliers it represents as a sales organization, and on behalf of distributors and other commercial partners. Forward Solutions processes such information only on the documented instructions of, and for the purposes directed by, those parties. The specific identities of these parties are confidential and are not published here; they are available to regulators, and to consumers to the extent applicable law (e.g., Oregon and Minnesota) requires disclosure of specific third parties, upon a verifiable request.

Categories of Personal Information Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) Your real name, alias, work postal address, unique personal identifier, online identifier, Internet Protocol address, work email address, or other similar identifiers.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Your work address, work phone number, work email address, employment, and/or employment history.
Characteristics of protected classifications under state or federal law. None.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) Records of products or services considered or inquired about.
Biometric information None.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Information regarding your interaction with an Internet Web site, application, or advertisement
Geolocation data None.
Audio, electronic, visual, thermal, olfactory, or similar information None.
Professional or employment-related information Publicly available information regarding your profession, current employer, and past employers.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) None.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Inferences drawn from any of the information identified above to create a profile about you reflecting your interest in certain products or services.

 

If you do not provide personal information required to provide products AND/OR services to you, it may delay or prevent us from providing products AND/OR services to you.

3. Cookie and Tracking Technology Policy

We use third-party cookies that help us analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. However, you can opt out of these cookies by checking "Do Not Sell or Share My Personal Information" and clicking the "Save My Preferences" button. Once you opt out, you can opt in again at any time by unchecking "Do Not Sell or Share My Personal Information" and clicking the "Save My Preferences" button.

4. How Your Personal Information is Collected.

We collect personal information from the following categories of sources:

  • You, directly in person, by telephone, text, or email
  • Third party with your consent (e.g., your bank)
  • Advertising networks
  • Internet service providers
  • Data analytics providers
  • Government entities
  • Operating systems and platforms
  • Social networks
  • Data brokers
  • Publicly accessible sources (e.g., property records)
  • Cookies and/or other tracking technology on our website and/or apps
  • Our IT and security systems, including:
    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email, and instant messaging systems.

5. How and Why We Use Your Personal Information.

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations
  • For the performance of our contract with you or to take steps at your request before entering into a contract
  • For our legitimate interests or those of a third party –or–
  • Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains our legitimate interests (what we use your personal information for and our reasons for doing so):

What we use your personal information for Our Reasons
To provide products AND/OR services to you For the performance of our contract with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or Forward Solutions For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity; Screening for financial and other sanctions or embargoes; Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator To comply with our legal and regulatory obligations.
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations.
Ensuring business policies are adhered to, e.g., policies covering security and internet use For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training, and quality control For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information;  To comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.
Preventing unauthorized access and modifications to systems For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you; To comply with our legal and regulatory obligations
Updating and/or enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract;  To comply with our legal and regulatory obligations;  For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products.
Statutory returns To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations;  For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
Marketing our services and those of selected third parties to:
• Existing and former customers
• Third parties who have previously expressed an interest in our services
• Third parties with whom we have had no previous dealings		 For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers.
Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts For our legitimate interests or those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards;  To comply with our legal and regulatory obligations.

6. Promotional Communications.

We may use your personal information to send you updates (by email, text message, telephone, or post) about our products AND/OR services including exclusive offers, promotions or new products AND/OR services.

Where applicable U.S. federal or state law requires consent before sending promotional communications, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and will only share it with those manufacturers whom we represent to provide you with products AND/OR services.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at marketing@forward-solutions.com
  • Using the "unsubscribe" link in emails or "STOP" number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business. We comply with the requirements of the CAN-SPAM Act, including providing clear identification of promotional messages, honoring opt-out requests promptly, and including our valid physical mailing address in all applicable communications.

7. Consequences of Withdrawing Consent; Processing Timeframes

Forward Solutions will process consent withdrawal requests within the following timeframes:

  • Marketing Emails: Typically processed immediately; may take up to 5 business days to fully reflect across all systems
  • SMS/Text Messages: Processed immediately upon receipt of a valid “STOP” request
  • Cookies: Processed immediately upon updating preferences in the Cookie Preference Center
  • Sensitive Data Requests: Processed within 10–30 days, depending on the nature and complexity of the request and applicable legal requirements

Consequences of Withdrawing Consent

Withdrawing your consent may impact your experience or our ability to provide certain services:

  • Marketing Emails: You will no longer receive promotional communications, but may still receive transactional or service-related messages
  • SMS/Text Messages: You will no longer receive text communications, but this will not affect your access to products or services
  • Cookies: Certain website features or functionality may be limited or unavailable, particularly where cookies are necessary for performance or personalization
  • Sensitive Data Processing: We may be unable to provide certain features or services that rely on that data

Contact for Assistance

If you experience any issues withdrawing your consent or have questions, please contact us at: datagovernance@forward-solutions.com

8. Who We Share Your Personal Information With.

We routinely share personal information with:

  • Our affiliates, including companies within the Forward Solutions group
  • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts
Recipient Data Type Recipient Category Purpose
Investors First Name, Last Name, Persona Processor Validate quality of earnings
Banks First Name, Last Name, Persona Processor Validate quality of earnings
Insurers & Brokers First Name, Last Name, Persona Processor Cybercrime Forensics, As Legally Required
Credit Reporting Agencies First Name, Last Name, Persona Processor As Legally Required
Government Entities First Name, Last Name, Title, Persona, Email Address, Postal Address, Phone Number Independent Controller As Legally Required
Service Providers First Name, Last Name, Persona, Email Address, Title Processor Cybercrime Forensics, As Legally Required, Product & Service Developments
Customers First Name, Last Name, Persona, Title, Email Address Processor Cybercrime Forensics, Product & Service Developments
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
  • Credit reporting agencies
  • Our insurers and brokers
  • Our bank[s]
  • Those manufacturers whom we represent to provide you with products AND/OR services.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, accreditation bodies, and those conducting the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

9. Personal Information We Have Not Sold or Shared.

In the preceding 12 months, we have not sold or disclosed to one or more third parties the following categories of personal 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:

  • Identifiers (e.g., a social security number, driver’s license number, passport number, or other similar identifiers);
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences.
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her signature, social security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
  • Characteristics of protected classifications under California or federal law;
  • Commercial information (e.g., records of personal property, products or services purchased, obtained);
  • Biometric information;
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, personal address, personal telephone number, personal email address, education; and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

10. Categories of Personal Information We Disclosed for a Business Purpose.

In the preceding 12 months, we have or may have disclosed the following categories of personal information for a business purpose:

  • Identifiers (e.g., a real name, alias, online identifier, Internet Protocol address, work email address, account name, or other similar identifiers)
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, business address, business telephone number,
  • Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement)
  • Professional or employment-related information

11. How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf
  • To show that we treated you fairly –or–
  • To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Routinely, our data retention period is thirty-six (36) months in active status, after which data is archived.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Category Retention Period
Account & Profile Information 7 Years
Transaction & Billing Records 7 Years
Marketing Communication Records 7 Years
Customer Support Records 7 Years
Website Usage & Analytics Data 7 Years
Employment Related Data 7 Years
SMS Text Messaging Consent Records 7 Years

12. California Consumers: Your Rights Under the CCPA/CPRA.

Our website does not currently respond to ‘Do Not Track’ browser signals. However, we honor the Global Privacy Control signal as described in the Universal Opt-Out Mechanisms section below.

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

  • The categories of personal information we have collected about you, including sensitive personal information;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting, selling, or sharing personal information;
  • The categories of third parties to whom we disclose personal information, if any; and
  • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the Do Not Sell or Share My Personal Information link here: www.onesolutionteam.com

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

  • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
  • To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and
  • As authorized by further regulations.

Since we use Sensitive Personal Information (SPI) in alignment with Cal. Civ. Code § 1798.121(d), the “Limit Use” link is not available on our website.

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, visit our homepage and click on the “Limit the Use of My Sensitive Personal Information” link here: www.onesolutionteam.com

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records;
  • Direct any service providers or contractors to delete your personal information from their records; and
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • 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;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

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

13. Other State-Specific Privacy Rights

In addition to the rights provided under the California Consumer Privacy Act (CCPA), residents of certain U.S. states may have additional privacy rights. These include, but are not necessarily limited to:

Colorado Residents

The Colorado Privacy Act (CPA) provides Colorado residents with the following rights:

  • Access their personal data;
  • Correct inaccuracies in their personal data;
  • Delete their personal data;
  • Obtain their personal data in a portable format;
  • Opt out of the processing of personal data for targeted advertising, sale of personal data, or profiling.
  • If we refuse to take action on your request, you may have the right to appeal our decision. Instructions on how to appeal will be included in our response to your request.

Connecticut Residents

Under the Connecticut Data Privacy Act (CTDPA), Connecticut residents have the right to:

  • Access their personal data;
  • Correct inaccuracies in their personal data;
  • Delete their personal data;
  • Obtain a copy of their personal data in a portable format;
  • Opt out of the processing of personal data for targeted advertising, sale of personal data, or profiling.
  • If we refuse to take action on your request, you may have the right to appeal our decision. Instructions on how to appeal will be included in our response to your request.

Florida Residents

  • The Florida Digital Bill of Rights (FDBR), Fla. Stat. § 501.701 et seq., grants enumerated consumer rights only with respect to a "controller" that meets the statute's applicability thresholds, including global gross annual revenue exceeding $1 billion and the additional criteria set forth in Fla. Stat. § 501.702. Forward Solutions does not meet these thresholds and is therefore not a covered "controller" under the FDBR. Accordingly, the consumer rights set forth in Fla. Stat. § 501.705 (including the rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling) do not apply to Forward Solutions' processing of Florida residents' personal information.
  • Forward Solutions remains subject to the Florida Information Protection Act, Fla. Stat. § 501.171, including its data-security and breach-notification requirements, and handles Florida residents' personal information in accordance with that statute and the other rights and choices described in this Privacy Policy.

Iowa Residents

Iowa residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to data portability;
  • Right to opt-out of targeted advertising, sale of personal data, and profiling.

Maryland Residents

Maryland residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to data portability;
  • Right to opt-out of targeted advertising and sale of personal data.

Minnesota Residents

Minnesota residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to data portability;
  • Right to opt-out of targeted advertising and sale of personal data.

Montana Residents

Montana residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to data portability;
  • Right to opt-out of targeted advertising and sale of personal data.

New Hampshire Residents

New Hampshire residents have the following rights:

  • Access, correction, deletion, and portability of their personal data;
  • Opt-out of targeted advertising, sale of personal data, or profiling.

Nebraska Residents

Nebraska residents have the right to:

  • Access their personal data;
  • Correct inaccuracies;
  • Delete their personal data;
  • Opt-out of targeted advertising, sale of personal data, and profiling.

New Jersey Residents

New Jersey residents have the following rights under the New Jersey Data Protection Act (NJDPA):

  • Right to access personal data;
  • Right to correct inaccuracies;
  • Right to delete personal data;
  • Right to data portability;
  • Right to opt-out of targeted advertising, sale of personal data, and certain profiling.

Oregon Residents

Oregon residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to correct inaccuracies;
  • Right to data portability;
  • Right to opt-out of targeted advertising, sale of personal data, and certain profiling.
  • Right to Obtain List of Third Parties (Effective July 1, 2025): You have the right to obtain a list of the specific third parties, other than processors, to whom the controller has disclosed the consumer’s personal data. Send your request to: DataGovernance@Forward-Solutions.com and receive a response within 10 working days.

Texas Residents

Texas residents have the following rights regarding their personal data:

  • Right to access;
  • Right to delete;
  • Right to correct inaccuracies;
  • Right to data portability;
  • Right to opt-out of targeted advertising, sale of personal data, and certain profiling.
  • We do not sell sensitive personal or biometric data in alignment with Tex. Bus. & Com. Code § 541.102(b)–(c).

Utah Residents

The Utah Consumer Privacy Act (UCPA) provides Utah residents with the following rights:

  • Access their personal data;
  • Delete their personal data;
  • Obtain their personal data in a portable format;
  • Opt out of the sale of their personal data or the processing of personal data for targeted advertising.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA), Virginia residents have the right to:

  • Access their personal data;
  • Correct inaccuracies in their personal data;
  • Delete their personal data;
  • Obtain a copy of their personal data in a portable format;
  • Opt out of the processing of personal data for targeted advertising, sale of personal data, or profiling.
  • If we refuse to take action on your request, you may have the right to appeal our decision. Instructions on how to appeal will be included in our response to your request.
  • Delaware: The Delaware Personal Data Privacy Act (DPDPA), effective January 1, 2025, provides rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and profiling. Delaware’s law has a notably broad scope, applying to entities that control or process data of 35,000 or more Delaware residents (or 10,000 residents if more than 20% of revenue derives from data sales).
  • Tennessee: The Tennessee Information Protection Act (TIPA), effective July 1, 2025, provides rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and profiling. Tennessee’s law includes a 60-day cure period for alleged violations.
  • Indiana: The Indiana Consumer Data Protection Act (INCDPA), effective January 1, 2026, provides rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and profiling.
  • Kentucky: The Kentucky Consumer Data Protection Act (KCDPA), effective January 1, 2026, provides rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and profiling.
  • Rhode Island: The Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA), effective January 1, 2026, provides similar consumer rights with notably low applicability thresholds (35,000 consumers, or 10,000 consumers if more than 20% of revenue derives from data sales).

If we decline to take action on your request, you have the right to appeal our decision. To submit an appeal, please contact us at DataGovernance@Forward-Solutions.com, with details of your original request and the reason for your appeal. We will review your appeal and respond in writing within 45 days of receipt. If we deny your appeal, we will provide you with an explanation of our decision and, depending on state law, you may have the right to submit a complaint to your state Attorney General.

14. Non-Discrimination.

We will not discriminate against you for exercising your privacy rights. This means we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services just because you exercised your rights under these state privacy laws.

15. Universal Opt-Out Mechanisms

Effective January 1, 2025, we will honor user-enabled global privacy controls (specifically including the Global Privacy Control or “GPC” signal) through a plugin provided by Cookie Yes that communicates or signals the consumer's choice to opt out of the sale and sharing of their personal information.

16. Automated Decision-Making and Profiling

We may use automated decision-making and profiling in certain circumstances. You have the right to:

  • Obtain human intervention
  • Express your point of view
  • Obtain an explanation of the decision reached
  • Challenge such decisions

17. Data Security Measures

We implement and maintain reasonable security procedures and practices appropriate to the nature of the personal information we collect and process. Our security program is formed in alignment with recognized industry frameworks, including the NIST Cybersecurity Framework and ISO/IEC 27001, and is aligned with SOC 2 Type II requirements, although Forward Solutions is not presently certified to those frameworks. These measures include:

  • Encryption of personal data at rest and in transit
  • Regular security assessments and penetration testing
  • Employee training on data protection and security best practices
  • Access controls and authentication mechanisms
  • Incident response and data breach notification procedures

Forward Solutions is committed to privacy by design and data protection by default, including data minimization in system design, privacy impact assessments for new products and services, and default privacy-protective settings.

18. Targeted Advertising Opt-Out

You have the right to opt out of the processing of your personal data for targeted advertising purposes. To exercise this right, please visit our "Do Not Sell or Share My Personal Information" page or use the following link: www.onesolutionteam.com

19. Data Protection Impact Assessments

We are working to formalize a data protection impact assessment for high-risk processing activities that would be likely to result in a high risk to individuals' rights and freedoms. These assessments will help us identify and minimize data protection risks.

20. Children's Privacy

Our services are not directed to children. We do not knowingly collect or process personal data from children under the age of 18 without parental consent. If we learn that we have collected personal data from a child under 18, we will take steps to delete the information as soon as possible. For residents of states with higher age thresholds for children's privacy protections, we will obtain parental consent as required by applicable law.

If you are a parent or guardian and believe your child has provided personal information to us, please contact us at: DataGovernance@Forward-Solutions.com. We will promptly investigate and take appropriate action, including deletion of the data.

21. SMS Messaging Privacy Policy.

This Messaging Privacy Policy explains how Forward Solutions collects and uses information about you in relation to its text message program (the “Messaging Service”). We use SimpleVoIP to provide the Messaging Service to you. For the purposes of the Messaging Service, SimpleVoIP acts as our service provider and data processor of your information.

Consent Disclosure

Consumers may revoke consent through any reasonable means, including but not limited to replying STOP, CANCEL, END, QUIT, or UNSUBSCRIBE. Opt-out requests will be honored within 10 business days. A confirmation message will be sent upon receipt of an opt-out request, and no further messages will be sent after that confirmation - other than the confirmation itself.

By providing their phone number and opting in, the consumer gives prior express written consent (as that term is used in 47 U.S.C. § 227(b)(1)(A) and 47 C.F.R. § 64.1200(a)(2)) to receive autodialed marketing and/or informational text messages from Forward Solutions; consent is not required as a condition of purchasing any goods or services; the types of messages that will be sent (e.g., promotional offers, service updates, appointment reminders); and message and data rates may apply. Opt-in consent data will be shared only with platform providers and vendors who assist in the delivery of text messages, and that such third parties are contractually prohibited from using the data for any purpose other than message delivery on Forward Solutions’ behalf. Our message frequency varies; message and data rates may apply, and the consumer’s carrier’s standard messaging rates apply.

Collection of Information. We collect various information on our behalf from and about you, including information you directly provide when you use the Messaging Service. For example, we collect the phone number you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages.

Use of Information. We use your information to deliver, analyze, maintain and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service.

Sharing of Information. We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:

Service Providers We may share your information with third parties to help us provide the Messaging Service to you.

Legal Requirement and Protection of SimpleVoIP and Others

We may disclose your information as we believe such disclosure is necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce a contract with us; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Protection of Information. We take a variety of physical, technical, administrative, and organizational security measures based on the sensitivity of the information we collect to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. Unfortunately, no online activity can be guaranteed to be 100% secure. While we strive to protect your information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide. We do not accept liability for unintentional disclosure.

Retention of Information. We retain your information for as long as you participate in the Messaging Service or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our customers, and enforce our agreements.

Choices and Controls. Consent to receive automated text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, QUIT, and STOPALL, and HELP which returns program information and a support contact.

For additional opt-out information, please review our Terms.

Customer Care. If you are experiencing any problems with the Messaging Service, please email (DataGovernance@forward-solutions.com).

By signing up to receive text messages from us, you also agree to our main Privacy Policy.

22. Cross-Border Data Transfers.

We may transfer your personal data to countries outside your jurisdiction. When we do so, we ensure appropriate safeguards are in place to protect your data consistent with applicable U.S. federal and state privacy laws, including contractual data-protection commitments with recipients and adherence to recognized privacy and security standards.

23. How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here using the webform at www.onesolutionteam.com or you may email us at Marketing@Forward-Solutions.com.

  • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
  • If you choose to contact us directly by email, you will need to provide us with:
    • Enough information to identify you (e.g., your full name, address and customer or matter reference number)
    • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
    • A description of what right you want to exercise and the information to which your request relates
  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
  • Authorized Agents. You may designate an authorized agent to submit a request to know, request to delete, request to correct, or request to opt-out of the sale or sharing of personal information, on your behalf. To do so, you must provide the authorized agent with written permission signed by you, and we may require you to (i) verify your own identity directly with us and (ii) directly confirm with us that you provided the authorized agent permission to submit the request. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. See Cal. Civ. Code § 1798.185(a)(7); 11 Cal. Code Regs. § 7063.
  • Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

24. Right to Data Portability.

Where applicable under U.S. state privacy laws (including, as applicable, the CCPA/CPRA and the comprehensive privacy statutes of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Tennessee, Indiana, Delaware, New Hampshire, New Jersey, Minnesota, Maryland, Rhode Island, and Kentucky), you have the right to request a copy of certain personal information in a structured, commonly used, and machine-readable format, and, where required by applicable law, transmit that data to another controller.

Format of Data Provided

Upon a valid request, Forward Solutions will provide portable personal data in one or more of the following formats:

  • JSON (JavaScript Object Notation)
  • CSV (Comma-Separated Values)
  • Other structured, commonly used, and machine-readable formats, where appropriate and technically feasible

The format provided will depend on the nature of the data and the systems in which it is stored.

Scope of Portable Data

The right to data portability applies only to personal data that:

  • Was provided directly by you
  • Is processed by automated means
  • Is processed by Forward Solutions in a structured, commonly used, machine-readable format

This may include, for example:

  • Account registration details
  • Contact information
  • Transaction or service usage data
  • The right does not apply to:
  • Data derived or inferred by Forward Solutions (e.g., analytics, scoring, or profiling data)
  • Data that Forward Solutions is required to retain or process to comply with legal, regulatory, or recordkeeping obligations
  • Data that would adversely affect the rights and freedoms of others, including trade secrets or personal data relating to third parties

Direct Transmission to Another Controller

Where technically feasible, you may request that Forward Solutions transmit your portable data directly to another data controller.

Forward Solutions will honor such requests where:

  • A secure and compatible transmission method exists
  • The receiving controller can accept the data in the provided format
  • If direct transmission is not feasible, we will provide the data to you so that you may transmit it independently.

Request Method and Response Timeframe

To exercise your right to data portability, you may submit a request via:

Email: datagovernance@forward-solutions.com

Forward Solutions will:

  • Acknowledge receipt of your request promptly
  • Verify your identity to protect your data
  • Respond within 30 days of receiving a valid request, unless a longer period is permitted by applicable law due to complexity or volume of requests

If additional time is required, we will notify you of the delay and the reason for it.

Limitations and Safeguards

Forward Solutions may decline or limit a portability request, where permitted by law, including where:

  • The request is manifestly unfounded or excessive
  • Identity cannot be verified
  • Fulfillment would infringe on the rights of others or compromise security

25. Transferring Your Personal Information.

To deliver services to you, it is sometimes necessary for us to share your personal information with our offices, affiliates, and service providers, including where there is an international dimension to the products and/or services we are providing to you.

We will ensure that any such transfer complies with applicable U.S. federal and state privacy laws and that appropriate contractual and technical safeguards are in place to protect your personal information. Business contacts and employee PII are fully within the scope of the CCPA/CPRA. The CCPA originally provided limited exemptions for personal information collected in the business-to-business context (Cal. Civ. Code § 1798.145(n)) and in the human-resources and employment context (Cal. Civ. Code § 1798.145(h), (m)). Those exemptions sunset on January 1, 2023, and have not been renewed. As a result, Forward Solutions treats personal information of California residents collected in connection with business contacts (including individuals acting on behalf of vendors, customers, and other businesses) and of its personnel (including employees, job applicants, owners, directors, officers, and contractors) as fully subject to the CCPA/CPRA. The consumer rights described in this Privacy Policy apply equally to those individuals, except where a specific statutory exemption continues to apply.

If you would like further information, please contact us (see "How To Contact Us" below).

26. Keeping Your Personal Information Secure.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach.

27. Data Breach Notification

Forward Solutions is committed to promptly identifying, assessing, and responding to any personal data breach in accordance with applicable U.S. federal and state data breach notification laws and industry best practices.

Notification to Regulators

In the event of a personal data breach, Forward Solutions will notify the applicable state attorneys general and other regulators required to be notified under applicable U.S. state data breach notification laws, within the timeframes and in the manner required by those laws.

Notification to Affected Individuals

Where a data breach is likely to result in a high risk to the rights and freedoms of individuals, Forward Solutions will notify affected individuals without undue delay, and in accordance with all applicable U.S. state data breach notification timelines and requirements.

Content of Breach Notifications

All breach notifications, whether to supervisory authorities or affected individuals, will include, to the extent known at the time:

  • A description of the nature of the breach, including the categories and approximate number of affected individuals and records
  • The likely consequences of the breach
  • A description of the measures taken or proposed to address the breach and mitigate its potential adverse effects
  • Contact information for a designated point of contact (e.g., Data Protection Officer or Security Team) for further inquiries

Forward Solutions may provide updates as additional information becomes available.

Notification Methods

Forward Solutions will use appropriate communication methods based on the nature and scope of the breach, including:

  • Email notification (primary method where feasible)
  • Direct written notice (e.g., postal mail)
  • Prominent website notice or public communication where direct notification is not feasible or would involve disproportionate effort

Internal Reporting of Suspected Breaches

All employees, contractors, and partners are required to immediately report any suspected or confirmed data breach to the designated security contact:

Security Contact: datagovernance@forward-solutions.com

28. Third Party Links.

Our website may contain links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

29. Accessibility.

The online Policy is designed to conform substantially to WCAG 2.1 Level AA.

30. Changes to This Privacy Policy.

We review and update this Policy annually. This privacy notice was published on [5/5/25] and last updated on [07/01/26].

We may change this privacy notice from time to time, and when we do, we will notify you of any material changes by posting the updated Privacy Policy on our website and updating the effective date.

31. Changes to This Privacy Policy

Forward Solutions may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational needs.

Definition of a Material Change

A “material change” includes, but is not limited to:

  • New or expanded purposes for processing personal information
  • New categories of personal information collected
  • New or expanded categories of third parties with whom personal information is shared
  • Changes that reduce or limit individuals’ rights under applicable law
  • Significant changes to data retention periods
  • Changes to how we use personal information in ways that may reasonably impact individuals

Notification of Material Changes

For any material change, Forward Solutions will provide affirmative notice to affected individuals, including:

  • Email notification to the individual’s registered email address
  • Provided at least 30 days prior to the change taking effect
  • Where required by law or appropriate, we may also provide notice through additional channels, such as prominent website banners or in-application notifications.

Acceptance and Consent

For processing activities that are not based on consent (e.g., contractual necessity, legitimate interests), your continued use of our services after the effective date of the updated Privacy Policy constitutes acknowledgment of the changes.

For processing activities that require consent (e.g., certain marketing activities, cookies, or processing of sensitive personal data), Forward Solutions will seek affirmative re-consent where required by applicable law before implementing the material change.

Version History and Transparency

Forward Solutions maintains a version history of this Privacy Policy to promote transparency and accountability.

Each version will include:

  • An effective date
  • Prior versions of this Privacy Policy may be made available upon request.

32. How to Contact Us

Please contact us by mail, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Forward-Solutions
Marketing@Forward-Solutions.com
305 Canal Street
Lamont, IL 60439

33. Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see "How to contact us" above). A Spanish-language version of this Privacy Policy is available on request; please contact us using the methods set forth above.

Last modified: June 22, 2026

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