Privacy Policy

Phase 5 Group, LLC

Privacy Notice

This Privacy Policy is effective as of May 25, 2018.

Phase 5 Group, LLC ("Phase 5 Group", "we" or "us"), a company incorporated and existing under the laws of Virginia, is committed to protecting and respecting your privacy and to ensuring the confidentiality and safety of your Personal Data.

This Privacy Policy provides information so that users and visitors are able to consent to the processing of their personal data, where appropriate. Please read the present Privacy Policy carefully and make sure you agree with its terms before registering for and/or (further) using the Service.

  1. Contact Information

The data controller is: Phase 5 Group, LLC

 

1420 Spring Hill RD, Suite 600 McLean, VA 22102

 

  1. Definitions

For the purposes of this Privacy Policy, the capitalized terms below will have the following meanings:

 

"Customer" means customers of Phase 5 Group having entered into a master subscription agreement;

 

"Personal Data" means all data or information relating to identified or identifiable Users and/or visitors collected by, submitted to, or otherwise processed by Phase 5 Group;

 

"Service" means the online, web-based eon.phase5group.com service, including associated offline components, and the Software provided by Phase 5 Group via designated websites;

 

"Software" means the online web-based eon.phase5group.com software service;

 

"User" means any Customer's employee, consultant, contractor or agent who is authorized to use the Service and has been supplied with a user identification and password by Customer (or by Phase 5 Group at Customer's request).

 

Visitor” means an individual who visits the Platform.

 

You” or “Your” means a User or Visitor.

 

  1. Scope of Our Privacy Policy

Phase 5 Group as a data processor. Most of the time we process Personal Data of Usersin the context of the delivering the Service pursuant to the instructions of our Customers, acting as a data processor. We commit ourselves to fully respect their instructions and to apply best practice security measures in order to protect your Personal Data.

 

However, these processing operations are not covered by the present Privacy Policy. For further information, please contact the Customer who has given you the authorization to use the Service.

 

Phase 5 Group as a data controller. We also act as a data controller by collecting and processing Personal Data of Visitors for our own purposes. This Privacy Policy provides further information with respect to these processing activities. Please read it carefully.

 

The Service contains links to third party websites. If you follow a link to such websites, please note that these websites and any services accessible through them are not governed by this Privacy Policy and that we do not accept any responsibility or liability for their privacy policies or processing activities.

 

  1. Categories of Personal Data Collected and Source of the Data

Personal Data Collected from Users

We collect information that you or the Customer that has given you the authorization to use the Service provides us with Personal Data about you. This includes information you or said Customer provide when registering to use the Service or when reporting a problem with the Service. We also collect information by analyzing a user’s behavior on the Services over time. This information is collected through cookies and similar technologies. For information about cookies see our Cookie Policy at Section 9.

The “Personal Data” that we collect and process through the Services or in connection with the Services include:

Name, contact details

In various sections of the Services users are asked to provide information about themselves. The information you give us includes your name, work e-mail address, phone number, name of your organization, your age, your function, your picture and other registration information (including information relating to your organization, such as the industry in which it is active).

Payment information

If a user requests Services for which payment is required, the user is asked to provide payment information. This information is collected and processed by an external payment processor; it is not accessed or stored by us.

Registered User Information

If a user registers on the Services, we create an account in the name of that registered user. Depending on the situation, we request:

  • First and Last Name
  • Company
  • Email address
  • Street address, including country
  • Telephone number
  • Age
  • Your industry and function within that industry
  • Picture

Only the minimum amount of information necessary to operate or manage the account is mandatory. The user may elect to provide additional information, which we use to enhance the Service, for example by offering access to social media accounts.

To access the user account, the registrant is required to create a password.

Communication from Users

When a user completes an online form, visits our Services (for example on social media), or when a user otherwise contacts us, by email, phone or text, we automatically collect and store certain information about that user and the user’s activities, as we receive from such user, for example:

  • The user’s name and contact information;
  • Information that the user provides to us;
  • The user’s company information, if any;
  • The nature of the communication;
  • The purpose of the interaction, and the action we took in response to the user’s inquiry or request;
  • Any action the user takes upon receipt of such communication (for example, whether the user registers to attend an event that we offer, or request to receive documentation).

The information collected in connection with each type of interaction is retained so that we can continue interaction with the requestor with respect to our Services or Services.

Communications to Users

Unless we are prohibited by applicable law from using cookies and a user has not otherwise consented to our use of cookies, we insert cookies in some of our correspondence.

In that case, when we send an email message to a user, our message contains images or links that when viewed or clicked, allow us to know whether the user has accessed or declined to open our message. This action will also store a cookie that allows us to count unique clicks or visits and potentially track the recipient.

This information helps us understand how the individual reacts to our communications and limit the amount and nature of information provided.

Personal Data Collected from Users and Visitors

Surveys and Contests

From time-to-time, we invite users to participate in surveys or contests. Participation is voluntary. These surveys are organized for the purposes of our marketing efforts. When a user participates, we request certain personal data such as name and email address.

This is necessary to ensure that responses are categorized properly and are not duplicated. Depending on the nature of the survey or contents, we also use this information to send the survey results to the participants, or, if applicable, to notify contest winners and award prizes.

We also use the information in aggregate form, for analytics purposes, to understand our market, to monitor site traffic or app usage, or to modify our Services or our Service to meet the needs or interests of users.

If we use a third-party service provider to conduct these surveys, the information collected by the service provider is subject to both the service provider’s privacy policy and ours. We will provide information about the applicable privacy policies with the Survey rules and will seek your explicit consent to these rules when required by law. You should read the terms of the survey or contest to understand the extent to which the service provider is allowed to use or reuse the information collected.

Social Media

Our Services offers integrations with third-party social media Services. These services collect the user’s IP address and which page of our Services the user is visiting. They will set a cookie to enable their features to function properly. Social media features and widgets are hosted by a third party or directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the feature.

Publicly Available Data

We also collect information available from publicly available directories, and information that has been made available be an individual on public for a, such as information about a person’s interests.

Other information

Certain areas of the Services include free text fields, where you can write messages to others, or post content that contain Personal Data. We request that you do not disclose:

  • Any data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data or data concerning your health, sex life or sexual orientation
  • Any social security number, national Identification number, financial account information or any other information that might be deemed highly sensitive or confidential.
  • Any data related to other persons.

Log Data

When a user or visitor uses, or interacts with our Services, or clicks on a link that directs the user or visitor to our Services, the user’s or visitor’s browser automatically provides, and we automatically collect and store, certain information about the user’s device (computer, tablet, smartphone) and the user’s or visitor’s activities. This includes:

  • Preferences and settings: time zone, language, and character size;
  • Identifiers: IP address
  • Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution;
  • Coarse Geographic information: geographic location derived from the IP address.

We collect this data for the proper operation of our Platform and Services. Until the visitor registers with us, this data cannot be linked to a specific individual.

Traffic Data

Data generated by the use of the Services also include: (for EEA users or visitors, if the user or visitor has accepted profiling cookie)

  • Information about the user’s or visitor’s use of the Services: date stamp, URL of the visited page, URL of the last webpage visited before visiting our Services or a website using our Services. URL of the last webpage visited before visiting our Service;
  • History of the user’s or visitor’s interaction with our webpages: pages viewed, time spent on a page, click through, clickstream data; queries made, search history, search results selected; comments made, type of service requested, purchases made.
  1. Purposes of processing

We use Personal Data for the following purposes:

Service

  • To allow users to create and maintain a registered user account, verify a user’s identity and assist user if he/she misplaces or forgets his/her login or password;
  • To respond to users’ inquiries, allow users to sign up for newsletters, request white papers, or other information, in order to contribute to or download our white paper or content;
  • To finalize purchase orders and deliver a Services to the user;
  • To carry out market research and surveys;
  • For interaction on social media;

Marketing

  • For marketing purposes via e-mail, text, phone, instant messaging, regarding our products and services, or those of selected third parties, such as sponsors;

Marketing to Existing Customers or Users

  • To interact with existing customers and users by sending marketing communications regarding products and services that are identical or similar to those the user has previously purchased or requested via the Services

Direct Marketing

  • By accepting the present Privacy Policy, you expressly acknowledge and accept that we may include your contact details, including your e-mail address, in our newsletter distribution list in order to provide you by e-mail with relevant marketing material, promotions, newsletters and any other information related to (direct) marketing purposes.
  • EEA visitors have other rights:  Unless you are a user or customer or we already otherwise have a relationship with you, will not send marketing material, promotions, newsletters, and other information for marketing purposes unless you have specifically contact us, or filled out one of our forms to request such material.

Profiling

  • To create a profile of a person as a Services user or visitor, through the use of profiling cookies (subject to our Cookie policy) and by collecting and analyzing information on the user’s or visitor’s interest to serve to each information and advertisements that may be relevant to that user or visitor. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias;

EEA users and visitors have other rights:  As stated in our Cookie Policy, we will not use profiling cookies unless you have opted-in to our use of these cookies.

Analytics

  • For development and administration of the Services, in order to improve our offerings and troubleshoot any technical issues which arise in connection with the use of the Services (“Analytics”);
  • The information is only used in the aggregate so that there is no access to any personal data of an identifiable person.

Enforcement, Misuse, or Fraud

  • To enforce the terms of this Privacy Policy and the master services agreement we entered into with the Customer and to prevent and detect any misuse of the Services or any fraudulent activities carried out through the Services (“Enforcement/Misuse/Fraud”).
  1. Legal Basis for the Processing

The grounds on which we rely to process Personal Data, according to the purposes identified include the following:

Purpose

Legal Ground

Mandatory/Not

Service

The information necessary to provide the Services, fulfil the request that you make, take steps before entering into a contract with you, or perform a contract entered into with you.

No

If you do not provide the information you need, we will not be able to provide certain Services to you over the Services

Marketing

The collection of information for marketing is needed for our legitimate interest so that we can understand our market and have opportunities to communicate with potential or current customers, users, or visitors so long that the use of the data is no overridden by the interest of the individual.

Some forms of marketing to certain users and visitors located in the European Economic Area require opt-in consent, and we will request such consent as applicable

No

Users and visitors have the right to object to the use of their personal data for marketing purposes.

There is no consequence for not providing the information.

A user or visitor who has previously consented to the use of personal data for marketing, can withdraw this consent at any time.

Marketing to Existing Customers or Users

Marketing to existing customers or users is based on our legitimate interest in expanding its relationship with individuals who have previously purchased or shown interest in goods or services provided by us that are identical or similar to those the individual has previously purchased or requested through the Services.

No

Users and customers can opt-out of these communications at any time.

Profiling

For some users or visitors located in the European Economic Area, processing is based on the user’s or visitor’s consent, collected by means of the cookie pop-up banner and/or a specific tick box required the prior opt-in consent of that user or visitor.

No

Users and visitors can elect to not consent to the collection of information about them through cookies.

There is no consequence for such refusal other than not being able to benefit from greater personalization when using the Services.

Analytics

We have a legitimate interest in understanding how users and visitors use its Services or Services or what information visitors seek on the platform, so that it can improve them accordingly both to enhance the user’s or visitor’s experience, and to troubleshoot technical issues.

No

Enforcement; Misuse; Fraud

We have a legitimate interest in preventing and detecting fraudulent activities or misuse of the Services for potentially criminal purposes.

No

 

  1. Categories of Recipients

We share Personal Data with the entities listed below.

We believe that our practices below are fair, lawful, and proportional in light of the legitimate interests and needs of our business, our legal obligations, and our obligations under our contracts; that they fairly address each individual’s legitimate rights and expectations in view of the context and purpose of the collection and use of the information collected; and are not intrusive or contrary to individuals’ rights.

 

Disclosure to Marketing Partners

In countries where such activities do not require prior explicit consent, we provide personal information of individuals to third party marketing companies, affiliates, advertising agencies, and data aggregation companies. These partner firms use this information to provide individuals with information on products and services that may be of interest.

 

In countries, such as in the European Economic Area, where such activities are restricted, we conduct these activities in accordance with applicable local laws.

 

The above does not apply to Personal Data of Customer End Users to which we might have access in the course of providing a Service.

 

Service Providers

We share information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with hosting, data analytics, information technology and infrastructure, order fulfillment, email delivery, auditing, and other related activities as necessary to perform the Services that the Customer purchased and to comply with our legal or contractual obligations. We provide only the information such service providers need to perform their designated functions. Our contracts with them prohibit them from using or sharing with others the information that we provide to them, or that they collect directly for purposes other than as directed by us.

 

Events and Tradeshows

If, in connection with an event or a tradeshow, an individual provides us with contact information, we assume that this constitute an affirmative explicit consent to our collection and use of this information for marketing purposes.

 

Some of the events or tradeshows in which we participate are organized and hosted by unaffiliated organizations. These entities require attendees to these events to provide information such as their name, email address, and/or phone number as part of the registration process. We cannot control this collection or use of information. We encourage you to read the privacy statements of any third parties to whom you provide information, as they control how such information is handled.

 

Affiliates Entities

We share information with entities that are under common ownership or control of our parent company (“Affiliates”). Subject to local law requirements, express preferences indicated by individuals, or our contractual obligations the terms of this information are used to promote the services offered by our Affiliates and for the purposes described in this Privacy Notice.

 

Fraud Prevention and Protection of Legal Rights

We use and disclose information to the appropriate legal, judicial or law enforcement authorities and our advisors and investigators (i) when we believe, in our sole discretion, that such disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or our property, our Customers, Customer Parties, or others; (ii) in order to enforce or apply the master subscription agreement concluded with the Customer or to investigate potential breaches, (iii) when an individual has abused the Services, exceeded the permitted use of the Service, gained unauthorized access to any Tool, engaged in spamming, denial of service attacks, use of malicious code, or similar attacks; (iv) to exercise or protect legal rights or defend against legal claims; or (v) to allow us to pursue available remedies or limit the damages that we sustain.

 

Law enforcement

We disclose Personal Data if a court, law enforcement or other public or government authority with appropriate jurisdiction so requests, and we believe, in our reasonable discretion, that such request was made in compliance with applicable law.

 

Corporate Reorganization

We transfer Personal Data to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of bankruptcy or corporate restructuring. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to policies that are consistent with the policies described in this Privacy Notice. Any information that any individual submits or that is collected after that transfer is subject to a new privacy policy adopted by the successor entity.

 

  1. Retention of Personal Data

Data uses

Retention period

Providing the Service

Retained as necessary to fulfil such purposes.

We retain the data as necessary to protect our interests related to potential liability.

Marketing and Profiling

Retained from the moment the user or visitor gives consent until consent is withdrawn.

Where it is not withdrawn, consent will be renewed at fixed intervals.

If consent is withdrawn or not renewed, Personal Data will no longer be used for these purposes.

We retain the data as necessary to protect our interests related to potential liability

Marketing to Customers, Users, and Visitors

Retained from the time when we receive it in the context of purchases or requests made via the Services until the user or visitor objects to this processing.

If a user or visitor objects to the processing, the Personal Data will no longer be used for these purposes.

We retain the data as necessary to protect our interests related to potential liability.

Compliance

Retained for the period required by the specific legal obligation or by the applicable law.

Analytics

Retained as long as necessary to fulfil the purposes for which it was collected, unless the user or visitor objects to the processing and there are no other legal grounds justifying the retention of the information.

Misuse, Fraud

Retained as long as necessary to fulfil the purposes for which it was collected, unless the user or visitor objects to the processing and there are no other legal grounds justifying the retention of the information.

 

  1. Cookies

In some countries, the law requires us to provide you with detailed information about the cookies that are set when you visit our Site. The law also requires that we obtain your consent to the use of certain types of cookies. This Cookie Policy aims to provide you with information about cookies, how we use them, and when applicable law how we request your consent.

What are “cookies”?

Cookies are small text files that are sent to a user’s or visitor’s browser by the website visited or when an email is opened. They are used for numerous different purposes, including to remember a user’s or visitor’s actions and preferences (for example, login data, language, font size, other display settings, etc.), so that the user or visito does not have to configure them again when visiting again the website, or when moving from page to page within a website. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website. They may also contain a unique ID code that allows tracking a user’s or visitor’s browsing activities within a website, for statistical or advertising purposes.

Cookies are often divided in two categories, “session cookies” which are automatically deleted when you close your browser, and “persistent cookies” which remain on your device until their pre-set expiration period expires.

 

When browsing a website, you receive first party cookies, which are sent by the website or third party cookies, which are sent from websites or web servers other than the website being visited.

 

You can find more information about cookies at this website: www.allaboutcookies.org.


Users or Visitors Located in the EEA

Users or visitors located in the EEA have the right to prohibit the use of certain cookies. Technical cookies such as cookies used to allow users or visitors to login, and functional cookies, such as those used to remember choices made by a user or visitor when accessing the website usually do not require prior consent. However, cookies used to create profiles on users or visitor and to send advertising messages that take into account the preferences revealed by users or visitor while browsing websites usually require prior consent from users or visitor, although this may vary according to the applicable law.

Technical Cookies v. Profiling Cookies

For some types of cookies, the consent of the website user or visitor may not be necessary. This is the case for “technical cookies” which are only used to send messages through an electronic communication network, or are needed to provide the user or visitor with the service that the user or visitor requests: this includes browsing or session cookies, which are used to allow the user to login, and functional cookies, which are used to remember choices made by a user or visitor when accessing the website, such as language, fonts, settings, or to remember the products selected for purchase. These cookies are essential for the proper operation of the functions offered by the website.

 

Some cookies, known as “profiling cookies” are used to create profiles of users or visitors, and to send advertising messages to users or visitors in line with the user’s or visitor’s preferences inferred from the user’s or visitor’s browsing the website. Certain laws, such as laws that apply to individuals in the EEA, require the affirmative consent of users or visitor.

 

How we Obtain your Consent

The first time you visit our Site or at any other time after you have deleted our cookies from your device, you will be presented with a notice informing you that the Site uses cookies, in accordance with applicable law. That notice will include a link to this Cookie policy.

 

If the notice contains a request to agree to the use of our profiling cookies, we will use these cookies if you express your consent by clicking on the appropriate box. If you decide to continue through our website after being presented with that notice, without clicking on the appropriate box, we will assume that we do not have your consent to set cookies as described in this policy.

 

First Party Cookies

Our website uses technical cookies for website operations and to allow users or visitors to use the website content and services, to activate website functions, and to configure the website according to the user’s or visitor’s choice, such as language or font size.

 

We also use analytics cookies, which allow us to understand how users or visitors use the website and to track traffic to and from the website, and profiling cookies to observe the user’s or visitor’s activities on the website to infer the user’s or visitor’s preferences, and send advertising messages in line with these preferences.

 

Analytics Cookies

We use Google Analytics to collect information that permits evaluation of the use of the Website, analysis of user’s or visitor’s behavior and improvement of user experience. Information about how to opt out of Google Analytics at: https://tools.google.com/dlpage/gaoptout.

 

Third Party Cookies

We also use third party cookies, owned by third parties, which act either as independence data controllers regarding their own cookies.

 

You may opt-out of receiving interest-based advertising as explained below. The opt-out may be provided through specific opt-out cookies. Please note that:

  • using a new computer or a different browser, upgrading certain browsers, or modifying or erasing a browser’s cookie file, may clear an opt-out cookie.
  • there are many more companies listed on these sites than those that place cookies on your device when you access our Services.
  • opting out of receiving interest-based advertising does not block all advertisements served to your device. You will continue receiving advertisements, but these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

 

  • To Control Advertising on Websites

You are able to block the use of cookies that are used to create a profile about you. For further information see:

Digital Advertising Alliance:
http://www.aboutads.info/choices/
http://www.aboutads.info
http://www.aboutads.info/consumers

Europe: http://youronlinechoices.eu

Network Advertising Initiative:
http://www.networkadvertising.org/choices/
http://www.networkadvertising.org
http://www.aboutads.info/consumers


Disabling or blocking cookies

You can also delete cookies at any time using the settings of your browser. Please review the “Help” section of your browser.

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

Cookies present on the Site

We use the following types of cookies:

  • Browsing or session cookies: these cookies are strictly necessary for the operation of the website, and/or to allow the user or visitor to use the website content and Services.
  • Analytics cookies: these cookies provide information that is used to understand how a website is used, and to track traffic to and from a website.
  • Functional cookies: these cookies are used to activate specific functions and to configure webpages according to the user’s or visitor’s preference such as font size or language.
  • Profiling cookies: these cookies are used to observe a user’s or visitor’s interest based on activities on a website, and to send advertisements that take these preferences into account.

 

The first party cookies present on the site are:

 

Technical Name

Cookie type, function, purpose

Duration

__hs_opt_out

This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies.

2 Years

__hs_do_not_track

This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, which still allows anonymized information to be sent to HubSpot.

2 Years

__hs_testcookie

This cookie is used to test whether the visitor has support for cookies enabled.

Session Cookie

hs_ab_test

This cookie is used to consistently serve visitors the same version of an A/B test page that they’ve seen before.

Session Cookie

hs_lang_switcher_choice

This cookie is used to consistently redirect visitors to the language version of a page in the language they’ve selected on this top-level private domain in the past (if such a language version exists).

 

<id>_key

When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login. The cookie name is unique for each password-protected page.

 

hs-messages-is-open (TTL 30 minutes)

This cookie is used on the visitor UI side so HubSpot can determine/save whether the chat widget is open for future visits. It resets after 30 minutes to re-close the widget after 30 minutes of inactivity

30 minutes

hs-messages-hide-welcome-message (TTL 1 day)

When you dismiss the welcome message in your messages tool, a cookie is set to prevent it from appearing again for one day.

1 day

__hstc

The main cookie for tracking visitors. It contains the domain, utk (see below), initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

2 Years

hubspotutk

This cookie is used for to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when de-duplicating contacts.

10 Years

__hssc

This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.

30 minutes

__hssrc

Whenever HubSpot changes the session cookie, this cookie is also set. We set it to 1 and use it to determine if the visitor has restarted their browser. If this cookie does not exist when we manage cookies, we assume it is a new session.

Session Cookie

messagesUtk

This cookie is used to recognize visitors who chat with you via the messages tool. If the visitor leaves your site before they're added as a contact, they will have this cookie associated with their browser. If you have a history of chatting with a visitor and they return to your site later in the same cookied browser, the messages tool will load your conversation history with that visitor.

 

driftt_aid

Anonymous identifier token

No limit

driftt_eid

End user identification token

No limit

driftt_sid

Identifier token for specific browser session

No limit

driftt_aaid

Tracks assigned ABM/Outbound rep for the duration of the session

No limit

driftt_wmd

Boolean indicating the user has dismissed the welcome message in this session

No limit

DFTT_LEAD_HAS_PREV_IDENTIFIED

Boolean indicating the user has previously provided an email address

No limit

_d_hsutk

Boolean indicating the HubSpot UTK has been checked (if integration is enabled)

No limit

  1. Choices Regarding Cookies and Advertising

Cookies

You may choose to block our Services and other sites from setting cookies by changing the settings of your browser. Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Services.

To learn more about cookies, you may wish to refer to.
All About Cookies: http://www.allaboutcookies.org/
Cookie Central: http://www.cookiecentral.com/faq/
Network Advertising: http://networkadvertising.org/.

To obtain information specific a browser you can refer to

Explorer: http://support.microsoft.com/kb/196955

Firefox: http://support.mozilla.org/en-US/kb/Cookies

Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

Opera: http://www.opera.com/browser/tutorials/security/privacy/

Safari: http://support.apple.com/kb/ph5042

Safari iOS: http://support.apple.com/kb/ht1677

Android: http://support.google.com/android/bin/answer.py?hl=en&answer=1722193

Blackberry: http://docs.blackberry.com/en/smartphone_users/deliverables/32004/Turn_off_cookies_in_the_browser_60_1072866_11.jsp

Windows Phone: http://www.microsoft.com/windowsphone/en-us/howto/wp7/web/changing-privacy-and-other-browser-settings.aspx

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

Interest-based Advertising Targeting Visitors

We use information collected about a user’s or visitor’s use of our Services to arrange for advertisements about our Service to be served to a user or visitor on third party’s websites in accordance with our e-Marketing Policy. To do so, our advertising service provider places or recognizes a unique cookie on the user’s or visitor’s browser and uses other techniques, such as pixel tags.

If you would like more information about this practice and to learn about your choices, please visit
http://www.aboutads.info or
http://www.networkadvertising.org.

Opt-out of Interest-based Advertising

You may opt-out of receiving interest-based advertising as explained below. The opt-out may be provided through specific opt-out cookies. Please note that using a new computer, using a different browser, upgrading certain browsers, or modifying or erasing a browser’s cookie file, may clear an opt-out cookie.

Please note that opting out of receiving interest-based advertising does not result in block all advertisements served to your equipment. You will continue receiving advertisements; these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

Please bear in mind that there are many more companies listed on these sites than those that place cookies on your device when you access our Services.

  • To Control Advertising on Websites

Digital Advertising Alliance:
http://www.aboutads.info/choices/
http://www.aboutads.info
http://www.aboutads.info/consumers

Europe: http://youronlinechoices.eu

Network Advertising Initiative:
http://www.networkadvertising.org/choices/
http://www.networkadvertising.org
http://www.aboutads.info/consumers

  • To Control Advertising on Mobile Applications

Users of mobile device who do not want to receive interest-based advertising may opt-out in several ways.

Ad Choices for Mobile devices: http://www.aboutads.info/appchoices (it is necessary to first download the AppChoices app from http://www.aboutads.info/appchoices).

To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings.
To limit Ad Tracking on an Apple device: https://support.apple.com/en-us/HT202074.
To limit Ad Tracking on an Android device: https://support.google.com/ads/answer/2662922.

  • Google Analytics

Information collected by the Google Analytics cookie is transmitted to, and stored by, Google in accordance with its privacy practices.

To see an overview of privacy at Google and how this applies to Google Analytics, please visit: https://support.google.com/analytics/answer/6004245.

To opt out of Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout.

  • Social Media

You can edit or remove the permissions you have granted us to use information from your connected social media accounts by using the application privacy settings on your social media account. See the following for instructions on how to change or remove third party access on each Services:

Twitter: https://help.twitter.com/en/managing-your-account/connect-or-revoke-access-to-third-party-apps
Facebook: https://www.facebook.com/help/262314300536014/
LinkedIn: https://www.linkedin.com/pulse/remove-third-party-apps-connected-your-linkedin-hector-rodriguez

 

  1. Transfers of Personal Data

Personal Data is collected and processed in several different countries. We provide services to individuals, users, visitors, or customers located across the globe. Subject to applicable law, the personal data that we obtain from or about Individuals is processed or transferred to data centers located throughout the world, such as the United States. The standards and laws that apply to the protection of personal data in these countries may be different from that which is afforded in the country where a is located.

 

We rely on decisions from the European Commission and standard data protection clauses adopted by the European Commission when exchanging data across borders or when engaging service providers to process personal data outside the EEA.

 

Individuals who are in the EEA and who request access to our Platform and Services are required to explicitly consent the proposed transfer or processing of their personal data outside the EEA.

 

  1. Security

Security of Personal data

We use commercially reasonable technical, organizational, and administrative safeguards to protect information within our control against unauthorized or unlawful access, use, modification, destruction, processing or disclosure, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody.

We limit access to our users’ and visitors’ personal data to only those employees and third parties who reasonably need access to it to perform the activities attached to their job responsibilities.

No transmission of information via the internet is completely secure. Although we do our best to protect your Personal Data, no security system or storage system can be guaranteed to be 100% effective or secure. Thus, we cannot guarantee that any information provided to us or collected by us will not be accessed, hacked, disclosed, altered, or destroyed by unauthorized parties.

For more information with respect to the implemented security measures you can request a copy of our security white paper at info@phase5group.com (mailto:info@phase5group.com).

Breach of Security

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “How to Contact Us” section.

Lost or Stolen Information.

You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will assist you in updating your account details.

  1. Rights of Individuals Located in the European Economic Area

The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) the following rights, with some limitations. Users and visitors may contact us, at the address provided in the “How to Contact us” section below, to exercise any of those rights and we will respond with the requested action or information, or will let you know why that right does not apply to you.

Right Not to Provide Consent or to Withdraw Consent

We seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdrawal.

Right of Access

You have the right to obtain confirmation as to whether or not we collect or process personal data concerning you and, if this is the case, you have the right to request a copy of such personal data in digital format.

Right of Rectification

You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.

Right of Erasure

In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.

Right to Restrict Processing

In certain circumstances, you have the right to request that we restrict the processing of the personal data that we have collected about you; for example, where you believe that the personal data that hold about you is not accurate or lawfully held.

Right to Data Portability

In certain circumstances, you have the right to receive the personal data concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the data to another entity where technically feasible.

Right to Object to the Processing

In certain circumstances, you have the right to request that we stop processing your personal data.

Right to Object to the Processing for Direct Marketing Purposes

You have the right to request that we stop sending you marketing communications.

Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects

In certain circumstances, you have the right no to be subject to a decision based solely on automated processing - including profiling - that produces legal effects or similarly affects you.

Right to Complain to a Supervisory Authority

You have the right to lodge complaint with a supervisory authority if you believe that our processing of personal data relating to you infringes the GDPR.

  1. Rights of Users and Visitors Located in California

California requires operators of websites or similar services to make certain disclosures to users or visitors who reside in California regarding their rights, specifically:

Shine the Light

Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed personal data that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California users or visitors, upon request, the identity of any such third party, along with the type of personal data disclosed.

You can contact us to as provided in the “How to Contact Us” section. Please note that under California law, businesses are only required to respond to a user’s or visitor’s request once during any calendar year.

Do-Not-Track

Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to users or visitors how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law.

In the meantime, there are technical means to prevent some of the tracking, if any. See Section “Your Advertising Choices.”

  1. Children’s Privacy

Our Services is not directed to individuals under the age of 13. We do not solicit or knowingly collect Personal data from such individuals. If you become aware that a child has provided us with personal data, please contact us as indicated in the “How to Contact Us” section below. If we obtain actual knowledge that we have collected Personal data from a child under the age of 13, we will take steps to delete such information from our database.

  1. Amendments

We reserve the right to amend or update this Policy at any time. We will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Services or later, as provided by applicable law. Please regularly visit this page to acquaint yourself with the latest, updated version of the Privacy Policy.

  1. How to Contact Us

The data controller is Phase 5 Group, LLC with a principal business address at 1420 Spring Hill RD, Suite 600 McLean, VA 22102.

Communications, questions and comments can be sent to Phase 5 Group, 1600 Spring Hill Road, Suite 230, Vienna, VA 22182, United States, or info@phase5group.com (mailto:info@phase5group.com).