2. THE PERSONAL DATA WE COLLECT
We may collect and process the following personal data about you:
2.1 Information that you give us.
2.1.1 This includes information you may give us so we can provide you with access to the Platform or Services and may include your name, address, e-mail address, phone number and other information necessary to use the Platform or Services.
2.1.2 When using the Platform or Service, you may also provide us with personal information about you and your employees so we can provide the Services.
2.2 Information that we collect automatically. We automatically collect the following information from your use of the Platform:
2.2.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if applicable), browser type and version, browser plug-in types and versions, operating system and platform; and
2.2.2 information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Platform (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, and methods used to browse away from the page and any phone number used to call our customer service number.
2.3 Information that we receive from third parties. We are working closely with third parties (including, for example, business partners, resellers, sub-contractors in technical and payment services, advertising networks, analytics providers and search information providers) and may receive information from them.
3. WHY WE COLLECT PERSONAL DATA AND WHAT WE DO WITH IT
3.1 When you provide your personal data to us, we will make reasonable efforts to ensure that the purpose for which you are providing that personal data is clear.
3.2 Depending on who you are and your relationship with us, we may process your personal data as follows:
3.2.1 to carry out our obligations to you from your use of our Platform, the Services or under another agreement with you;
3.2.2 to administer your account with us;
3.2.3 to provide you with information about our products, the Platform, the Services and any other services we provide;
3.2.4 to administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.5 to allow you to participate in interactive features of the Platform or Service, when you choose to do so;
3.2.6 internally, to inform decisions about our business operations and strategy; and
3.2.7 to contact you from time to time to market any other services we provide and we think may be of interest to you.
4. WHO WE SHARE YOUR PERSONAL DATA WITH
4.1 We may disclose your personal information:
4.1.1 to business partners, suppliers and sub-contractors for the performance of any contract we or you enter into with them or to fulfill our Services to you;
4.1.2 to our customers in order to allow them to use our Service;
4.1.3 in the event that we sell or transfer any part of our business or assets (whether by merger, asset sale or otherwise), in which case we may disclose and transfer your personal data to the prospective buyer of such business or assets;
4.1.4 if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; and
4.1.5 to third parties to enforce agreements between us or to investigate potential breaches of those agreements or to protect the rights, property or safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. SECURITY MEASURES FOR THE PLATFORM
5.1 We implement a variety of technical, administrative and organizational security measures for the Platform and Services that we believe are commercially reasonable to help us maintain the safety of your personal information when you place an order or enter, submit or access your personal information. These security measures include using one or more servers for the Platform and Services that are secured by commercially reasonable measures.
5.3 You are responsible for keeping confidential your access credentials for the Platform or Service, including password(s), and you should not share your password(s) with anyone.
5.4 Notwithstanding the above, you should be aware that the transmission of information via the Internet is not completely secure. Although we will use commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted using the Services or the Platform, and as a result, any transmission of personal data is at your own risk.
6.2 A cookie is a small file that a site or its service provider transfers to the hard drive of your computer or other device through your Web browser and enables the site or service provider systems to recognize your browser and capture certain information for use during your visit to our Platform and for future visits to our Platform.
6.3 We use the following cookies:
6.3.1 Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform, use a shopping cart or session tracking.
6.3.2 Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily.
6.3.3 Functionality cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences.
6.3.4 Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We may also share this information with third parties that assist us with our Platform and fulfilling our Services for you.
6.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform and use the Services. In addition, if you delete any Platform cookies on a given visit, you would need to block them again in subsequent visits to our Platform.
7. CHILDREN’S PRIVACY AND AGE LIMITATIONS FOR THE PLATFORM
7.1 The Platform is intended for use by persons aged 18 or older. We do not knowingly collect personally identifiable information from persons under the age of 18. If we discover or are made aware that we have received personally identifiable information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will delete such information from our systems. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed personally identifiable information to us, please contact us as provided below. In any such event, a parent or guardian of a child under the age of 18 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.
8. ADDITIONAL NOTICES TO CALIFORNIA RESIDENTS
8.1 California Do-Not-Track Disclosure. At this time, the Platform is not set up to honor web browser do-not-track settings.
8.2 Information on Marketing Disclosures. California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared 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 to us at Phobio, 800 Battery Ave SE Suite 100, Atlanta, GA, 30339 or at email@example.com.
9. LINKS TO OTHER WEBSITES
11. GENERAL INFORMATION TO CONTACT US
12. ADDITIONAL NOTICES TO EUROPEAN UNION CITIZENS
Persons who are residents of the member countries of the European Union (“EU”) or other data subjects covered by the EU’s General Data Protection Regulation, (EU) 2016/679 (the “GDPR”), have certain additional privacy rights under applicable law. The following provisions of this Section 12 provide an overview of these additional rights.
12.1 Legal Bases for Processing Personal Information of European Union Citizens or Other GDPR Data Subjects
When processing your personal information, Phobio may rely on one or more of the following legal bases (or other available legal grounds), depending on the circumstances:
(a) Legitimate Interests – Phobio may process your personal information where Phobio has a legitimate interest in such processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.
(b) Consent – Phobio may process your personal information where Phobio has obtained your consent to the processing.
(c) Contractual Necessity – Phobio may process your personal information where such processing is necessary in connection with any contract that Phobio has with you.
(d) Legal Requirements – Rodio may process your personal information where such processing is required by applicable law.
12.2 Disclosures to Third Parties
Rodio may also disclose any information (including personal information) relating to you to law enforcement authorities or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.
12.3 Security of Personal Information of European Citizens or Other GDPR Data Subjects
Rodio has policies and technical and organizational measures in place which are intended to safeguard and protect your personal information against unauthorized access, accidental loss, improper use and disclosure. However, you should be aware that information transmitted over the internet is not completely secure because of the nature of the internet and that systems and measures used to secure information are not flawless. For these reasons, although Rodio will use reasonable efforts to protect your personal information, Rodio does not warrant the security of personal information transmitted to Rodio or stored by Rodio, and personal information that is transmitted to Rodio by you electronically is done at your own risk.
12.4 Retention of Personal Information of European Citizens or Other GDPR Data Subjects
Rodio’s policy is to retain your personal information only for as long as is necessary to fulfill the purposes for which Rodio collected such personal information, including for the purposes of satisfying any professional, legal, accounting or reporting requirements to which Rodio is subject. To determine the appropriate retention period for personal information, Rodio considers the scope, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which Rodio collected and processed your personal information and whether Rodio can achieve those purposes through other means, and any applicable legal and professional requirements.
12.5 Your Rights as a European Citizen or Other GDPR Data Subject
You have a number of rights concerning your personal information that Rodio holds and uses, including the following:
(a) Right of Access – You have the right to be informed about what personal information Rodio holds about you and to a copy of this personal information.
(b) Right to Rectification – You have the right to have any inaccurate personal information which Rodio holds about you updated or corrected.
(c) Right to Erasure – In certain circumstances you may request that Rodio delete the personal information that Rodio holds about you.
(d) Right to Complain – You have the right to lodge a complaint regarding the processing of your personal information to an applicable governmental or supervisory authority in your country.
(e) Right to Withdraw Consent – Where processing of personal information is based on your consent, you have the right to withdraw such consent at any time.
(f) Right to Object – Where Rodio relies on our legitimate interests to process your personal information, you have the right to object to such use and Rodio is required to discontinue such processing unless Rodio can demonstrate an overriding legitimate interest in such processing.
(g) Right to Restriction – You have the right to request that Rodio stop using your personal information in certain circumstances including if you believe that the personal information Rodio holds about you is inaccurate or that Rodio’s use of your personal information is unlawful. If you validly exercise this right, Rodio will store your personal information and will not carry out any other processing until the issue is resolved.
You may exercise any of the above requests in writing to Rodio, 10945 State Bridge Rd, Ste 401-707, Alpharetta, Georgia 30022 or at firstname.lastname@example.org. You are also free at any time to request that Rodio stop using your personal information for marketing purposes by contacting us at Rodio, 10945 State Bridge Rd, Ste 401-707, Alpharetta, Georgia 30022 or at email@example.com