This privacy notice for Phoenix (“Company,” “we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you: 

Visit our website at https://pnxns.com or any website that links to this privacy notice. 

Engage in other related ways, including sales, marketing, or events. 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not access or use the Services, Websites, or any other aspect of Phoenix’s business. If you still have any questions or concerns, contact us at [email protected]. 

1. PERSONAL INFORMATION YOU DISCLOSE TO US 

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you participate in activities on the Services, or when you contact us. 

Personal Information Provided by You: 

The personal information we collect depends on the context of your interactions with the Services and us, your choices, and the products and features you use. The personal information we collect may include the following: 

• names 
• phone numbers  
• email addresses  
• mailing addresses  

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

Information automatically collected: 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our website. 

We automatically collect certain information when you visit pnxns.com, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes. 

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes the following: 

Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings). 

Device Data. We collect device data such as information about your computer, phone, tablet, or other devices you use to access the Services. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. 

Location Data. We collect location data, such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information by refusing access or disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services. 

1. HOW DO WE PROCESS YOUR INFORMATION? 

We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. 

We process your personal information for various reasons, depending on how you interact with our Services, including to save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest and prevent harm. 

1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? 

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. 

This section applies to you if you are in the EU or UK. 

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: 

Consent. We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.  

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. 

Vital Interests. We may process your information where it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person. 

If you are located in Canada, this section applies to you. 

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. 

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:  

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way 
• For investigations and fraud detection, and prevention 
• For business transactions, provided certain conditions are met 
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim 
• Identifying injured, ill, or deceased persons and communicating with next of kin. 

• If we have reasonable grounds to believe an individual has been, is, or maybe a victim of financial abuse. 
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province. 
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records 
• If an individual produced it in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced, If the collection is solely for journalistic, artistic, or literary purposes. 
• If the information is publicly available and is specified by the regulations 

1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 

In Short: We may share information in specific situations described in this section and/or with the following third parties. 

We may need to share your personal information in the following situations: 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

Business Partners. We may share your information with our business partners to offer certain products, services, or promotions. 

1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 

In Short: We may use cookies and other tracking technologies to collect and store your information. 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.  

1. HOW LONG DO WE KEEP YOUR INFORMATION? 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than 2 years. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is impossible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible. 

1. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through organizational and technical security measures. 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. 

1. DO WE COLLECT INFORMATION FROM MINORS? 

In Short: We do not knowingly collect data from or market to children under 18 years of age. 

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from children under the age of 18, please contact us at [email protected] 

1. WHAT ARE YOUR PRIVACY RIGHTS? 

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 

You have certain rights under applicable data protection laws in some regions (like the EEA, UK, and Canada). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv), if applicable, to data portability. In certain circumstances, you may also have the right to object to processing your personal information. You can make such a request by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE section?” below. 

We will consider and act upon any request in accordance with applicable data protection laws. 

Suppose you are located in the EEA or UK, and you believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

Withdrawing your consent: If we rely on your consent to process your personal information, which may be expressed and/or implied consent, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. 

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send or by contacting us at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. 

If you have questions or comments about your privacy rights, email us at [email protected]. 

1. CONTROLS FOR DO-NOT-TRACK FEATURES 

Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. 

1. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below. Include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but please be aware that the data may be partially or comprehensively removed from all our systems (e.g., backups, etc.). 

CCPA Privacy Notice 

The California Code of Regulations defines a “resident” as: 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and 

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose 

All other individuals are defined as “non-residents.” 

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information. What categories of personal information do we collect? 

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:  

• Receiving help through our customer support channels 
• Participation in customer surveys or contests and 
• Facilitate the delivery of our Services and respond to your inquiries. 

How do we use and share your personal information? 

This privacy notice can find more information about our data collection and sharing practices. 

Please contact your account manager to submit any privacy inquiries or refer to the contact details at the bottom of this document. 

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. 

Will your information be shared with anyone else? 

We may disclose your personal information with our service providers pursuant to a written contract between each service provider and us. Each service provider is a for-profit entity that processes the information on our behalf. 

We may use your personal information for business purposes, such as undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information. 

Phoenix has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Phoenix will not sell personal information to website visitors, users, and other consumers in the future. 

Your rights with respect to your personal data 

Right to request deletion of the data — Request to delete 

You can ask for the deletion of your personal information. Suppose you ask us to delete your personal information. In that case, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. 

Right to be informed — Request to know. 

Depending on the circumstances, you have a right to know: 

• Whether we collect and use your personal information 
• The categories of personal information that we collect 
• The purposes for which the collected personal information is used 
• Whether we sell your personal information to third parties 
• The categories of personal information that we sold or disclosed for a business purpose 
• The categories of third parties to whom the personal information was sold or disclosed for a business purpose 
• The business or commercial purpose for collecting or selling personal information. 

In accordance with applicable law, we are not obligated to provide or delete consumer information de-identified in response to a consumer request or re-verify a consumer request. 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights, We will not discriminate against you if you exercise your privacy rights. Verification process 

Upon receiving your request, we will need to verify your identity to determine whether you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. 

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification. However, we cannot verify your identity from the information already maintained by us. In that case, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you. 

Other privacy rights 

You may object to the processing of your personal information. 

You may request correction of your data if it is incorrect or no longer relevant or ask to restrict the processing of the information. 

You can designate an authorized agent to make a request under the CCPA on your behalf. We may only accept a request from an authorized agent who submits proof that they have been validly authorized to act on your behalf per the CCPA. 

You may opt-out of future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, by fifteen (15) days from the request submission date. 

To exercise these rights, you can contact us. Please contact your account manager to submit any privacy inquiries or refer to the contact details at the bottom of this document. If you complain about how we handle your data, we would like to hear from you. 

1. DO WE MAKE UPDATES TO THIS NOTICE? 

In Short: Yes, we will update this notice to stay compliant with relevant laws. 

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. 

1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 

If you have questions or comments about this notice, email us at [email protected].  

1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to [email protected].