Privacy Policy

Last Updated: [June 23, 2022]

This Privacy Policy pertains to Phoenix Manufacturing and its related entities and their affiliates (collectively “Phoenix”, “we”, “us”, or “our”) and informs our users (“user(s)”, “you”, or “your”) about how we may collect and use the personal information that you provide on our websites (our “Sites”), the manner in which we may use such information, how we protect it, and the choices available to you regarding our use of your personal information.

We may modify or supplement this Privacy Policy from time to time by posting those changes on this page. Any changes will become effective as of the date of posting. Please review this Privacy Policy often so you are always fully informed of any changes.

This Privacy Policy is binding on all those who access, visit, and/or use our Sites and the services associated with the Sites (collectively, the “Services”), whether acting as an individual or on behalf of an entity.  If you do not agree to be bound by this Privacy Policy, then do not access or use the Sites or the Services.

This Privacy Policy is part of our Terms of Use, which govern your use of the Sites and Services. By using our Sites, contacting us to inquire about our Services or products, or otherwise providing us with information, you consent to our Privacy Policy and agree to our Terms of Use.

This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties, which are governed by their respective privacy policies.

If you have any questions about this Privacy Policy, please contact us as directed below.

Collection and Retention of Information

When you visit our Sites, we may ask you to provide certain information about yourself, including your name, mailing address, email address, and phone number. This and other personal information may be collected when you do the following:

  • Request information from us through our “Contact Us” page or by signing up for an account, email updates or newsletters;
  • Contact us regarding products or services or to request a quote;
  • Apply for employment with us;
  • Purchase products or services through our Sites;
  • Post user-generated content on any of our Sites; or
  • Otherwise interact with our Sites or our representatives.

In other instances, we (or qualified contractors/vendors on our behalf) may automatically collect some non-personally identifiable computer information regarding your use of our Sites, such as the type of computer operating system you are using and the web browser that you are using, as well as information regarding your Internet service provider, IP address, device characteristics, device location and the frequency with which you visit various parts of our web sites.

For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you.  If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

We may use various methods and technologies to store or collect usage data (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your device. A few of the Tracking Technologies used on the Sites, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

  • Cookies.  A cookie is a file placed on a device to uniquely identify your browser or to store information on your device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
  • Web Beacons.  A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Sites’ pages and messages.
  • Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on.
  • ETag, or entity tag.  An Etag or entity tag is a feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting.  Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
  • Recognition Technologies.  Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including:

  • To allow you to use and access the Sites, including for the prevention of fraudulent activity and improved security functionality;
  • To assess the performance of the Sites, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Sites;
  • To offer you enhanced functionality when accessing the Sites, including identifying you when you sign into our Sites or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
  • To deliver content relevant to your interests on our Sites and third‑party sites based on how you interact with our advertisements and/or content.

We may, from time to time, offer forums or the ability to comment or post content through some of our Sites. If you post personally identifiable information on our Sites, you should be aware that such information could be read, collected or used by other users. We are not responsible for any personally identifiable information you choose to publish through such forums.

Children’s Data Protection and Parental Responsibility

We recognize the importance of children’s safety and privacy. Our Sites are not designed to attract children and are not intended for use by any children under the age of 13. We do not request, or knowingly collect, any personally identifiable information from children under the age of 13. Minors under the age of 16 (but older than 12) may use the Sites only under the supervision of a parent or legal guardian who agrees to be bound by the Sites’ Terms of Use.  If you are the parent or guardian of a child under 13 who has provided her or his information to us, please contact us at [email protected] to request the deletion of that information.

Our Use and Disclosure of Information

We may use your information (email address, telephone number, etc.) to:

  • Respond to requests for product information and quotes;
  • Fulfill purchases of products and services;
  • Follow-up with you when you have submitted information via the Contact Us portion of the Sites,
  • Send you marketing information about our products and services (including the products and services of our related entities);
  • Send you email communications and newsletters, improve the effectiveness of our Sites;
  • Understand more information about the users of our Sites;
  • Protect the security and integrity of our Sites;
  • Comply with applicable laws, rules and regulations;
  • For internal business purposes; and
  • For any other purposes disclosed to you at the time you provide your information to us or as otherwise described in this Privacy Policy.

We may share the information that we collect as necessary with our third-party agents or contractors, who assist in providing support for our internal operations and with whom we have obtained contractual confidentiality obligations regarding user information and, unless you have withdrawn your consent to such sharing or have expressed a preference otherwise, with our corporate affiliates if your interaction with us indicates that you may be interested in the products and/or services of those affiliates.

We also may use this information to notify you of new or special programs and offerings. If you do not want any such updates, simply opt out of those communications by sending an email to [email protected], indicating “Privacy Opt Out” in the subject line. You may opt-out any time by selecting the “unsubscribe” option at the bottom of the email.

We may aggregate, de-identify, and/or anonymize any information collected through the Sites or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-personal information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

We also may share your information, including your personal information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including personal information, as disclosed at the time you provide your information and as described in this Privacy Policy.

We may use email addresses and usernames to track usage and to ensure users are following our Terms of Use. In addition, we may use an email address, username, or IP address to ban a user temporarily or permanently from any Site that the user engages in any inappropriate manner. WE RESERVE THE RIGHT TO TEMPORARILY OR PERMANENTLY BAN ANY USER AT ANY TIME WHO VIOLATES OUR TERMS OF USE.

We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena, or where we disclose information to data processors who act on our behalf (service providers or other group companies who provide support for the operations of our Sites and who do not use or disclose the information for any other purpose). To the extent permitted by applicable law, we also may disclose personally identifiable information in response to a law enforcement agency’s request or other public agency’s (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our Sites protect the security or integrity of our Sites and networks, and/or enable us to take precautions against liability, misuse or unauthorized use.

If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or business transfer, we may transfer personally identifiable information to a third party as part of that transaction, to the fullest extent permitted by applicable law and your use of our Sites pursuant to this Privacy Policy evidences your consent thereto.

Consent and Removal

By using our Sites, providing us with your information and/or completing a transaction with us (as applicable in your jurisdiction), you are consenting to our collection and use of your information, as provided above. You may revoke this consent at any time by contacting us at the contact information provided below and your subscription will be cancelled and no such further access to our Sites will be available.

Security

We incorporate commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Sites, and you provide us with your information at your own risk.

If you have any questions about security on our Services or if you become aware of any unauthorized use of an account or suspect a security breach, notify us immediately via email at [email protected]. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

Linked Websites

For your convenience, the Sites and this Privacy Policy may contain links to other websites. We are not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Sites should be deemed to imply that we endorse or have any affiliation with the links.

Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

If you are a resident of or located within the European Economic Area (EEA), you have certain additional data protection rights.  These rights include:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your personal information.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Legal Basis for Processing Personal Information Under GDPR

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the personal information we collect and the specific context in which we collect it.

We may process your personal information because:

  • We need to perform a contract with you;
  • You have given us permission to do so;
  • The processing is in our legitimate interests and it is not overridden by your rights; or
  • To comply with the law.

Retention of Information

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

We will also retain usage data for internal analysis purposes. Usage data is data collected automatically either generated by the use of the Sites or from the Sites’ infrastructure itself (for example, the duration of a page visit). Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites or we are legally obligated to retain this data for longer periods.

Transfer of Information

Your information, including personal information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including personal information, to United States and process it there.

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

We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Personal Information

Disclosure for Law Enforcement – Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

We may disclose your personal information in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend our rights or property
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Information

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

Please note that we may ask you to verify your identity before responding to such requests.

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your personal information first.

For more information, please contact your local data protection authority in the EEA.

Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request and obtain a list of what personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties.  Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to [email protected].

Changes in this Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Sites.  Please refer to this policy regularly. If at any time we decide to use personal information in a manner different from that stated at the time it was collected, we will notify you either on the panel homepage of our Sites or via email.

Contact Us

If you have questions or concerns with respect to our Privacy Policy, you may contact us at [email protected].