For more information, see our Privacy Policy. Got it! Decline PRIVACY POLICY PHOENIX MARKETING INTERNATIONAL PRIVACY STATEMENT (UPDATED: June 21, 2021) We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification. INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE You are free to explore www.phoenixmi.com. When you visit our Website, we may request that you provide Personal Information about yourself, and we collect Navigational Information. PERSONAL INFORMATION YOU GIVE US This is information about you that you give to us by entering information via the Site or our social media pages or by corresponding with us by phone, email or other means and is provided by you entirely voluntarily. The information you give to us can include your name, contact details (such as phone number, email address and postal address), job title, employer’s name, enquiry details, your opinion of our products and services and certain marketing preferences. If you do not provide this information to us we may not be able to contact you and/or resolve your queries effectively. INFORMATION WE COLLECT ABOUT YOU FROM YOUR USE OF THE SITE Each time you use the Site we automatically collect the following information: the following technical information: a unique identification code for our authentication system, the internet protocol (IP) address of your device and details regarding the type of browser software you use to access the Site; details of your use of the Site, namely traffic data, weblogs and other communication data, including where and when you clicked on certain parts of the Site and details of the webpage from which you visited it; and cookie, pixel and beacon identification information (for more information about these, please see our Cookie Policy). We may record telephone conversations when you call us for training and monitoring purposes. If you do not provide this information, you may be unable to access some or all of the Site or its features. INFORMATION WE COLLECT ABOUT YOU FROM OTHER SOURCES If an organization for whom you work subscribes with us or one of our group companies, we will receive your name, job title, work location/address, email address and telephone number from them or the group company with whom they subscribe. We require this information to setup your account, which is a requirement of our contract with our client whose subscription you use. If you do not provide this information, we will be unable to provide you with access to our subscription service. HOW WE USE INFORMATION WE COLLECT Compliance with Our Privacy Policy We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy. We Never Sell Personal Information We will never sell your Personal Information to any third party. Use of Personal Information In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: improve your browsing experience by personalizing the Websites and to improve the Subscription Service; send information or Phoenix content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business; promote use of our services to you and share promotional and information content with you in accordance with your communication preferences; provide other companies with statistical information about our users — but this information will not be used to identify any individual user; send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements meet legal requirements. If you are a visitor/customer located in the European Economic Area (“EEA”),Research Horizons, LLC d/b/a Phoenix Marketing International located in Rhinebeck, New York, USA is the data controller of your personal information. Phoenix Data Protection Officer can be contacted at privacy@phoenixmi.com. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are. Use of Navigational Information We use Navigational Information to operate and improve the Websites and the Subscription Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Phoenix. Use of Credit Card Information If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf. Security of your Personal Information We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures. Social Media Features Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. External Websites Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have. Public Forums We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below. RETENTION OF PERSONAL INFORMATION How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible. We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements). When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below. If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Phoenix account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. International Transfer of Information To facilitate our global operations, we transfer information to either EU or the United States and allow access to that information from countries in which the Phoenix affiliated entities have operations for the purposes described in this policy. This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. When we share information about you within and among Phoenix’s affiliated entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area. Please see our Privacy Shield notice below for more information. International transfers to third parties Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area, we make use of the EU-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer. Please see our Privacy Shield Notice below. Compliance with EU-U.S. Privacy Shield Framework Phoenix Marketing International complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information. Phoenix Marketing International has certified to the Department of Commerce that it adheres to the Privacy Shield. To learn more about the Privacy Shield program please visit this link: Privacy Shield Website Via the Privacy Shield Framework, Phoenix Marketing International is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, individuals may invoke binding arbitration using the measures and policies outlined in this document. PMI will comply with the Onward Transfer Principle of the Privacy Shield including the responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Phoenix Marketing International shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage. Phoenix Marketing International is legally required to disclose personal information in response to lawful requests by public authorities, including any disclosures needed to meet national security or law enforcement requirements. WHEN WE SHARE INFORMATION We employ third parties who provide services for us such as website or application hosting, data analysis infrastructure provision, IT services, quality control, validation, auditing services, modeling services, and other similar services. We work with other companies for the purposes of data processing or market research product development purposes. These companies are contractually required to keep this information confidential and are not permitted to use this information for any other purpose except to carry out the services that they are performing for us. In accordance with market research guidelines, we may also provide individual level information to other companies. If we do, they are bound to keep the information confidential and use it only for marketing, research, or statistical purposes. If your individual information is used in this manner, you will be notified at the time of collection and you may request that we delete your information and/or opt-out of the sharing of your information using the “How to Access & Control Your Personal Data” section of this policy. We may share your respondent screening data, information collected via the Phoenix tracking pixel (including cookie ID, mobile device ad ID or IP address), as well as data identified from additional databases with third-party partners for their unaffiliated marketing purposes and Phoenix clients. They may use this data to conduct marketing research work of their own in aggregate, not at the individual level. This could include marketing effectiveness for advertising campaigns, media planning, understanding market trends or building advertising targeting models. Regardless of the use case for this data, all third-parties are prohibited from using any information we provide for the purpose of directly retargeting or recontacting you, or any other individual, via their advertising, surveying or other methods. We will provide the information to a third party if the law requires it or if it allows us to exercise our legal rights or take action regarding potentially illegal activities, or to protect the safety or rights of any person or legal entity. If all or part of our company is sold, merged or otherwise transferred, we may transfer the information as part of that transaction and will take steps to ensure that the information is protected as described in this Notice. COOKIES Phoenix uses cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy. HOW TO ACCESS & CONTROL YOUR PERSONAL DATA Reviewing, Correcting and Removing Your Personal Information You have the following data protection rights: You can request access, correction, updates or deletion of your personal information. You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA and certain non-European countries (including the US and Canada) are available here.) To exercise any of these rights, please contact us at privacy@phoenixmi.com. To Unsubscribe From Our Communications You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at privacy@phoenixmi.com. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service. CONTACT If you have any questions regarding PMI’s privacy policy, please contact us. Phoenix Marketing International c/o Chief Privacy Officer 6423 Montgomery Street, Suite 12 Rhinebeck, NY 12572 Phone: 845-876-8228 Fax: 845-876-8284 Email: privacy@phoenixmi.com TOP Subscribe to Free Marketing Insights © 2021 Phoenix Marketing International. 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