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Last updated: June 24, 2024

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service, and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words whose initial letter is capitalized have definite meanings under the following conditions. The following definitions will have the same meaning regardless of whether they appear in the singular or the plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Service or portions of our Service.
  • Business, for purposes of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects personal information from consumers and determines the purposes and means of processing consumers’ personal information, or on behalf of which such information is collected and that alone,  or in conjunction with others, determines the purposes and means of processing the personal information of consumers, who conduct business activities in the State of California.
  • Company (referred to as “the Company,” “We,” “Us,” or “Our” in this Agreement) refers to Phoenix Capital Group Holdings LLC, 18575 Jamboree Rd., Suite 830 Irvine, CA 92612.
  • Consumer, for purposes of the CCPA (California Consumer Privacy Act), means a natural person who is a resident of California. A resident, as defined by law, includes (1) any person who is in the U.S. for purposes other than a temporary or transitory purpose, and (2) any person who is domiciled in the U.S. and is outside the U.S. for a temporary or transitory purpose.
  • Cookies are small files that are placed on your computer, mobile device or other device by a website, and contain details of your browsing history on that website, among other uses.
  • Country refers to: California, United States.
  • Device means any device that can access the Service, such as a computer, mobile phone, or digital tablet.
  • Do Not Track (DNT) is a concept promoted by the regulatory authorities of the United States, in particular the Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism that allows Internet users to control the tracking of their online activities on different websites.
  • Personal Data refers to any information that relates to an identified or identifiable person.
  • For purposes of the CCPA, personal data means any information that identifies, relates to, describes, or can be associated with, or reasonably can be linked, directly or indirectly, with you.
  • Sale, for purposes of the CCPA (California Consumer Privacy Act), means selling, renting, release, disclosing , disseminating, making available, transferring, or otherwise communicating, orally, writingly, electronically, or by other means, a consumer’s personal information to another business or to a third party in exchange for monetary or other valuable consideration.
  • Service refers to the Website.
  • Service Provider refers to any natural or legal person who processes data on behalf of the Company. Refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform Service-related services, or assist the Company in analyzing how the Service is used.
  • Subsidiary refers to any company or venture owned by the parent, with the parent holding 51% or more the entity.
  • Usage Data refers to data collected automatically, generated both by the use of the Service and by the infrastructure of the Service itself (for example, the duration of a visit to a page).
  • Website refers to Phoenix Capital Group, accessible from https://www.phxcapitalgroup.com/.
  • You mean the person accessing or using the Service, or the company or other legal entity on behalf of which such person accesses or uses the Service, as applicable.

Collection and Use of Your Personal Data

Types of data collected

Personal data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Email address
  • Name and surname
  • Phone Number
  • Address, state, province, zip code, city
  • Bank account information to pay for products and/or services within the Service
  • Usage Data

When you pay for a product and/or service by bank transfer, we may ask you for information to facilitate this transaction and verify your identity. Such information may include, but is not limited to:

  • Date of birth
  • Passport or national identity card
  • Bank card statement
  • Other information that links you to an address

Usage Data

Usage data is collected automatically when you use the Service.

Usage data may include information such as the Internet Protocol address (e.g., IP address) of the device, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID of your mobile device, the IP address of your mobile device, the mobile operating system you use, the type of mobile Internet browser you use,  Unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service through a mobile device.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track activity on our Service and store certain information. The tracking technologies used may include beacons, tags, and scripts to collect and track information, as well as improve and analyze our Service. The technologies we use may include:

Cookies or Browser Cookies: A cookie is a small file that is placed on your device. You can instruct your browser to refuse all cookies or to alert you when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser settings to refuse cookies, our Service may use cookies.

Flash Cookies: Certain features of our Service may use locally stored objects (or flash cookies) to collect and store information about your preferences or activity on our Service. Flash cookies are not managed by the same browser settings that are used for browser cookies. For more information on how you can delete Flash cookies, see “Where can I change my settings to disable or delete local shared objects?” available on https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects

Web beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs) that allow the Company, for example, to count users who have visited those pages or opened an email, and to obtain statistics related to the website (e.g.,  record the popularity of a certain section and check the integrity of the system and server).

Cookies can be “Persistent” or “Session”. Persistent cookies remain on your personal computer or mobile device when you are offline, while session cookies are deleted as soon as you close your web browser. You can learn more about cookies in the article on the TermsFeed website.

We use both session cookies and persistent cookies for the following purposes:

Necessary / Essential Cookies

  • Type: Session cookies
  • Managed by: About Us
  • Purpose: These cookies are essential to provide you with the services available through the website and allow you to use some of its features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you have requested cannot be provided, and we only use them to provide those services to you.

Policy Acceptance Cookies / Cookie Notice

  • Type: Persistent cookies
  • Managed by: About Us
  • Purpose: These cookies identify whether users have accepted the use of cookies on the website.

Functionality Cookies

  • Type: Persistent cookies
  • Managed by: About Us
  • Purpose: These cookies allow us to remember choices you make when you use the website, such as remembering your login details or language preferences. The purpose of these cookies is to provide you with a more personalized experience and to prevent you from having to re-enter your preferences each time you use the website.

Tracking and Performance Cookies

  • Type: Persistent cookies
  • Managed by: Third parties
  • Purpose: These cookies are used to track information about traffic on the website and how users use the website. The information collected through these cookies can directly or indirectly identify you as an individual visitor. This is because the information collected is usually linked to a pseudonymous identifier associated with the device you use to access the website. We may also use these cookies to test new pages, features or functionality of the website and see how our users react to them.

Targeting and Advertising Cookies

  • Type: Persistent cookies
  • Managed by: Third parties
  • Purpose: These cookies track your browsing habits to allow us to display advertising that you are more likely to find interesting. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers may place cookies to display ads that we believe are relevant to your interests while you are on third-party websites.
  • For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy or the Cookies section of our Privacy Policy.

Use of your Personal Data

The Company may use personal data for the following purposes:

  • To provide and maintain our Service, including monitoring the use of our Service.
  • To manage your account: manage your registration as a user of the Service. The personal data you provide gives you access to different functionalities of the Service that are available to you as a registered user.
  • For the performance of a contract: the development, performance and performance of the contract for the purchase of products, items or services that you have purchased, or any other contract with us through the Service.
  • To contact you: communicate with you by email, phone calls, text messages or other equivalent forms of electronic communication, such as push notifications from a mobile application, about updates or informational communications related to the functionalities, products or services contracted, including security updates when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or consulted, unless you have opted out of receiving such information.
  • To manage your requests: attend and manage your requests to us.
  • To provide you with personalized advertising: We may use your information to develop and display content and advertising (and work with third-party providers who do so) tailored to your interests and/or location, and measure their effectiveness.
  • For business transfers: We may use your information to evaluate or carry out a merger, sale of assets, restructuring, dissolution or other transaction or transfer of all or part of our assets, whether as a going concern or as part of a bankruptcy, liquidation or other similar proceeding, in which personal data we hold about users of our Service is transferred as part of the assets.
  • For other purposes: We may use your information for other purposes, such as analyzing data, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our Service, products, services, marketing, and your experience.

We may share your personal information in the following situations, excluding any partners, providers, or other entities that would use personal information for promotional or marketing purposes:

  • With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our Service, to help maintain and support our Service, advertise on third-party websites after you have visited our Service, process payments, and communicate with you.
  • For Business Transfers: We may share or transfer your personal information in connection with, or during negotiations related to, any merger, sale of Company assets, financing, or acquisition of all or part of our business by another company.
  • With Subsidiaries: We may share your information with subsidiary companies, in which case we will require them to abide by this Privacy Policy. This may include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under our common control.
  • With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
  • With other users: When you share personal information or interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside of our control.
  • With your consent: We may disclose your personal information for any other purpose with your consent.
  • We will not share users’ phone numbers with business partners, subsidiaries, or affiliates for marketing or promotional purposes.

Retention of your Personal Data

The Company will retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

In addition, the Company will retain usage data for internal analysis purposes. Generally, usage data is retained for a shorter period of time, except when used to strengthen the security or improve the functionality of our service, or when we are legally obliged to retain such data for longer periods.

The Transfer of your Personal Data

Your information, including personal data, is processed at the Company’s operational offices and any other place where the parties involved in the process are located. This means that this information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and your personal data will not be transferred to an organization or country unless there are adequate controls in place, including the security of your data and other personal information.

Disclosure of your Personal Data

Commercial Transactions

If the Company is involved in a merger, acquisition or sale of assets, your personal data may be transferred. We will provide you with notice before your personal data is transferred and is subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests from public authorities (e.g. a court or government agency).

Other Legal Requirements

The Company may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate potential misconduct related to the Service
  • Protect the personal safety of users of the Service or the general public
  • Protect against legal liability

Security of your Personal Data

The security of your personal data is important to us, but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

Detailed information on the processing of your personal data

The service providers we use may have access to your personal data. These third-party providers collect, store, use, process and transfer information about your activity on our service in accordance with their privacy policies.

Analysis

We may use third-party service providers to monitor and analyze the use of our service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and generates reports on website traffic. Google uses the collected data to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt out of making your activity on the Service available to Google Analytics by installing the Google Analytics opt-out add-on in your browser. This add-on prevents Google Analytics JavaScript code (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.

For more information about Google’s privacy practices, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy

Advertising

We may use service providers to display advertisements that help you maintain and support our service.

Google AdSense & DoubleClick Cookie

Google, as a third-party provider, uses cookies to display ads on our service. Google’s use of the DoubleClick cookie allows it and its partners to display ads to our users based on their visit to our service or other websites on the Internet.

You can opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Google’s Ads Settings page: http://www.google.com/ads/preferences/

Email Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send you or by contacting us.

We may use email marketing service providers to manage and send emails.

Twilio

Their Privacy Policy can be found at https://www.twilio.com/legal/privacy

Payments

We may offer paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS, as administered by the PCI Security Standards Council, which is a joint effort of brands such as Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

When you use our Service to pay for a product and/or service by bank transfer, we may ask you to provide information to facilitate this transaction and verify your identity.

Remarketing Conductual

The Company uses remarketing services to show you ads after you have accessed or visited our Service. We and our third-party vendors use cookies and non-cookie-based technologies to help us recognize your device and understand how you use our Service, so that we can improve our Service and display ads that are likely to be of most interest to you.

These third-party providers collect, store, use, process and transfer information about your activity on our Service in accordance with their privacy policies and to allow us to:

  • Measure and analyze traffic and browsing activity on our Service
  • Show you ads for our products and/or services on third-party websites or applications
  • Measure and analyze the performance of our advertising campaigns

Some of these third-party providers may use non-cookie-based technologies that are not affected by browser settings that block cookies. Your browser may not allow you to block such technologies. You can use the following third-party tools to opt out of the collection and use of information to show you interest-based advertising:

You can opt out of personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Turn Off Ad Personalization (Android). Check your mobile device’s help system for more information.

We may share information, such as encrypted email addresses (if available) or other online identifiers collected on our Service, with these third-party vendors. This allows our third-party vendors to recognize and show you ads across different devices and browsers. For more information about the technologies used by these third-party providers and their cross-device capabilities, please refer to each provider’s privacy policy below.

The third-party providers we use are:

Google Ads (AdWords)

The Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt out of Google Analytics for display advertising and personalize Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics opt-out browser add-on, available on https://tools.google.com/dlpage/gaoptout. This add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information about Google’s privacy practices, please visit Google’s Privacy & Terms page: https://policies.google.com/privacy

Facebook 

Facebook’s remarketing service is provided by Facebook Inc.

You can learn more about Facebook’s interest-based advertising by visiting this page: https://www.facebook.com/help/516147308587266

To opt out of receiving interest-based ads from Facebook, follow these instructions provided by Facebook: https://www.facebook.com/help/568137493302217

Facebook complies with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance. You may also opt out of receiving interest-based ads from Facebook and other participating companies through the Digital Advertising Alliance in the U.S. http://www.aboutads.info/choices/, the Digital Advertising Alliance of  Canada in Canada http://youradchoices.ca/ or  the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or through your mobile device settings.

For more information about Facebook’s privacy practices, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Usage, Performance and Others

We may use third-party service providers to improve our Service.

Invisible reCAPTCHA

We use an invisible captcha service called reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA service may collect information from you and your device for security purposes.

The information collected by reCAPTCHA is treated in accordance with Google’s Privacy Policy: https://www.google.com/intl/es/policies/privacy/

Privacy under the CCPA

This California Resident Privacy Notice section supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others residing in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, can be associated with, or could be linked, directly or indirectly, with a particular consumer or device. Below is a list of categories of personal information that we may collect or that have been collected from California residents in the past twelve (12) months.

Please note that the categories and examples provided in the following list are those defined in the CCPA. This does not mean that all examples of that category of personal information have been collected by us, but it reflects our good faith and, to the best of our knowledge, that some information of that category has been collected. For example, certain categories of personal information would only be collected if you directly provided that personal information to us.

Category A: Identifiers.

Examples: Real name, alias, mailing address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Categories of personal information listed in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)).

Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state ID number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or other financial information, medical information or health insurance information. Some personal data included in this category may coincide with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including family genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, facial and voice recognition, iris or retinal scans, physical patterns such as the way you write or walk, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our service or advertising.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

Category H: Sensory data.

Examples: Auditory, electronic, visual, thermal, olfactory or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past work history or performance evaluations.

Collected: No.

Category J: Nonpublic educational information (under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Educational records directly related to a student maintained by an educational institution or a party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: A profile that reflects a person’s preferences, characteristics, psychological tendencies, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

  • Publicly available information in government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the scope of the CCPA, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Privacy of Health Information Act (CMIA), or clinical trial data.
  • Personal information covered by sector-specific laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver Privacy Protection Act of 1994.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, through the forms you fill out on our Service, the preferences you express or provide through our Service, or from your purchases on our Service.
  • Indirectly from you. For example, by observing your activity on our Service.
  • Automatically from you. For example, through cookies that we or our service providers set on your device as you browse our Service.
  • From service providers. For example, third-party service providers who monitor and analyze the use of our Service, third-party service providers who provide advertising on our Service, third-party service providers who deliver targeted advertising to you, third-party service providers for payment processing, or other third-party service providers we use to provide the Service to you.

Use of Personal Information for Commercial or Business Purposes

We may use or disclose the personal information we collect for “business” or “business” purposes (as defined in the CCPA), which may include the following examples:

  • To operate our Service and provide our Service to you.
  • To support you and respond to your inquiries, including investigating and addressing your concerns, and monitoring and improving our Service.
  • To fulfill or satisfy the reason you provided the information. For example, if you share your contact information to ask a question about our Service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, a court order, or government regulations.
  • As disclosed to you when collecting your personal information or as set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, where necessary, prosecuting those responsible for such activities.

Please note that the examples provided above are illustrative and are not intended to be exhaustive. For more details on how we use this information, please see the “Use of your personal data” section.

If we decide to collect additional categories of personal information or use the personal information we collect for materially different, unrelated or incompatible purposes, we will update this Privacy Policy.

Disclosure of Personal Information for Commercial or Business Purposes

We may use or disclose, and may have used or disclosed in the past twelve (12) months, the following categories of personal information for business or business purposes:

  • Category A: Identifiers
  • Category B: Categories of Personal Information Listed in California State Law on Customer Records (California Civil Code Section 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information have been disclosed, but it reflects our good faith belief, to the best of our knowledge, that some of that information of the relevant category has been disclosed.

When we disclose personal information for commercial or business purposes, we enter into a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose other than the performance of the contract.

Sale of Personal Information

As defined by the CCPA, “sell” and “sale” mean selling, renting, disclosing release, disseminating, making available, transferring, or otherwise communicating, orally, in writing, or by electronic or other means, a consumer’s personal information by business to a third party in exchange for valuable consideration. This means that we may have received some kind of benefit in exchange for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information have been sold, but it reflects our good faith belief, to the best of our knowledge, that some of that information in the relevant category has been shared in exchange for a value.

We may sell and have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Categories of Personal Information Listed in California State Law on Customer Records (California Civil Code Section 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Sharing Personal Information

We may share your personally identifiable information in the categories listed above with the following categories of third parties:

  • Service Providers
  • Payment Processors
  • Our affiliates
  • Our Business Partners
  • Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you

Sale of Personal Information of Children Under 16

We do not knowingly collect personal information from children under the age of 16 through our Service, although some third-party websites to which we link may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children’s internet usage and instruct them never to provide information on other websites without their permission.

We do not sell the personal information of Consumers who we know to be under the age of 16, unless we receive affirmative authorization (the “right to opt-in”) from the Consumer who is between the ages of 13 and 16, or from the parent or guardian of a Consumer under the age of 13. Consumers who choose to participate in the sale of personal information may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request through our contact.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us providing sufficient detail so that we can delete that information.

Your Rights Under the CCPA

The CCPA gives California residents specific rights regarding their personal information. If you are a California resident, you have the following rights:

  • Right to be notified: You have the right to be informed about the categories of Personal Data being collected and the purposes for which the personal information is being used.
  • Right to Request: Under the CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes, and sharing of personal information. Once we receive and confirm your request, we will disclose the following to you:
    • The categories of personal information we have collected about you.
    • The categories of sources from which we have collected personal information about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we have collected about you.
    • If we have sold your personal information or disclosed your personal information for a business purpose, we will disclose the following to you:
    • The categories of personal information sold.
    • The categories of personal information disclosed.
  • Right to Opt Out of the Sale of Personal Data (Opt Out): You have the right to tell us not to sell your Personal Information. To submit an opt-out request, please contact us.
  • The right to delete Personal Data: You have the right to request deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and also instruct our Service Providers to delete) your personal information from our records, unless there is an exception. We may deny your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which we collected the personal information, provide a good or service you have requested, take reasonably anticipated actions within the context of our ongoing business relationship with you, or perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that affect existing intended functionality.
    • Exercise freedom of expression, guarantee the right of another consumer to exercise their rights of freedom of expression, or exercise another right established by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in scientific, historical, or statistical research in the public interest or peer-reviewed that complies with all other applicable ethics and privacy laws, where deletion of the information would make it impossible or seriously impair the achievement of the research, if you have previously given your informed consent.
    • Allow internal uses only that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your rights as a consumer, including:
    • Deny you goods or services.
    • Charge you different prices or fees for goods or services, including the use of discounts or other benefits, or impose penalties on you.
    • Provide you with a different level or quality of goods or services.
    • Suggest that you will receive a different price or rate for goods or services, or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

To exercise any of your rights under the CCPA, if you are a California resident, you may contact us:

Visit this page on our website: https://www.phxcapitalgroup.com/contact/

Only you, or a person registered with the California Secretary of State whom you authorize to act on your behalf, may make a verifiable request regarding your personal information.

Your application must:

  • Provide sufficient information to enable us to reasonably verify that you are the person from whom we collected personal information or an authorized representative.
  • Describe your request in sufficient detail to allow us to understand, evaluate, and respond appropriately.

We cannot respond to your request or provide you with the required information if we are unable to:

  • Verify your identity or authority to make the request
  • And confirm that personal information relates to you

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period for providing the required information may be extended once for another 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period prior to receipt of the verifiable request.

For data portability requests, we will select a format for providing your personal information that is easily usable and that allows you to transmit the information from one entity to another without hindrance.

Do Not Sell My Personal Information

You have the right to opt out of selling your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt out of selling, please contact us.

Service providers with whom we collaborate (for example, our analytics or advertising partners) may use technology in the service that sells personal information as defined by the CCPA. If you wish to opt-out of the use of your personal information for interest-based advertising and potential sales purposes as defined by the CCPA, you may do so by following the instructions below.

Please note that any opt-out is specific to the browser you use. You may need to opt out for each browser you use.

Website

You may opt out of receiving personalized advertisements provided by our service providers by following the instructions presented on the service:

Opting out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the option to opt out of using information about the apps you use to show you ads targeted to your interests:

  • “Opting out of interest-based ads” or “Opting out of ad personalization” on Android devices.
  • “Ad tracking limit” on iOS devices.

You can also stop the collection of location information from your mobile device by changing the preferences on your device.

“Do Not Track” Policy as required by the California Online Privacy Protection Act (CalOPPA)

Our service does not respond to “Do Not Track” signals.

However, some third-party websites track your browsing activities. If you visit these types of websites, you can set your preferences in your web browser to inform the websites that you do not want to be tracked. You can enable or disable the “Do Not Track” option by visiting your web browser’s preferences or settings page.

Children’s Privacy

Our service is not directed to anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you become aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from someone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires parental consent, we may need your parent’s consent before collecting and using that information.

Your California Privacy Rights (California Shine the Light Act)

In accordance with California Civil Code Section 1798 (California Shine the Light Act), California residents who have an established business relationship with us may request information once a year about the sharing of their personal data with third parties for those third parties’ direct marketing purposes.

If you wish to request more information under California’s Shine the Light law and are a California resident, you may contact us using the contact information provided below.

California Underage User Privacy Rights (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 permits California residents under the age of 18, who are registered users of websites, services, or online applications, to request and obtain removal of content or information they have publicly posted.

To request deletion of such data, if you are a California resident, you may contact us using the contact information provided below and include the email address associated with your account.

Please note that your request does not guarantee complete or comprehensive removal of content or information posted online, and that removal may not be permitted or required by law in certain circumstances.

Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be redirected to that third-party site. We strongly encourage you to review the privacy policy of each website you visit.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will inform you by email and/or by means of a prominent notice on our service prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Policy.

It is recommended that you review this Privacy Policy periodically for changes. Changes to this Privacy Policy will be effective when posted on this page.

Contact us

If you have any questions about this Privacy Policy, you can contact us: