(Last updated 04 October 2020)
2. Acceptance And Use
3. Data Protection Principles
We collect, process and use personal data (in accordance with the definitions of the European General Data Protection Regulation (GDPR)) in order to provide our services. Personal data means any information that enables us to identify you, directly or indirectly, such as name, e-mail, address, telephone number, any form of identification number, or one or more factors specific to you or your beneficiary's identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up-to-date;
- Kept only as long as necessary for the purposes we have told you about;
4. Types of Data We Collect From You
When you make a purchase on our website, we acquire some data from you, such as:
- Personal Identifiable Information (PII): We acquire PII that may include, in specific contexts, your Full name, Social Media, and e-mail address;
- Financial Information: Bank account information, Credit Card data, or billing information are collected by an authorized third-party payment provider (PayPal) on behalf of Phanoon Limited (please see the Payment Process section);
- Sensitive PII: Information about the transactions you make on our Services, such as the names, mobile number, e-mail address, and other information about the directly connected accounts to your account, which are attracted to our service by you;
- Correspondence: Survey responses, the information provided to our support team or user research team.
5. Non-Personal Information
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or web site visitations). Phanoon Limited may collect non-personal information through any of the methods discussed above, as well as automatically through the use of industry-standard technologies described further below.
6. Information Collected Through Technology
While you visit the Phanoon Limited site and decide not to make a purchase on our website, Phanoon Limited website or its third-party service providers may still collect non-personal information about your use of the website (e.g., your internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). The following methods may gather such information:
- Cookies: Cookies including local shared objects, are small pieces of information that are stored by your browser on your device's hard drive, which works by assigning to your computer a unique number that has no meaning outside of the Phanoon Limited site. Cookies do not generally contain any personal information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the Phanoon Limited materials unavailable to you.
- IP address: You may visit many areas of the Phanoon Limited site anonymously without the need to become a registered user. Even in such cases, Phanoon Limited may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Phanoon Limited site and each time you request one of Phanoon Limited' pages, the server logs your IP address.
- Beacons: Beacons are small pieces of data embedded in web pages and e-mails. Phanoon Limited may use these technical methods in html e-mails that Phanoon Limited sends to users to determine whether they have opened those e-mails or clicked on links in those e-mails.
7. Other Information You May Submit
You may submit data to us for limited purposes such as requesting customer support, answering a questionnaire, participating in a study, entering contests or sweepstakes, or signing up to receive communications from another user or us.
8. Automatically-Collected Information
9. Information We Collect From You Automatically
We receive and store certain types of information automatically, such as whenever you interact with or use the Phanoon Limited website. This information helps us address customer support issues, improve the performance of the Phanoon Limited website, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
- Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, or personal IP addresses.
- Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
For example, we may automatically receive and record the following information on our server logs:
- How you came to and used the Phanoon Limited website;
- Device type and unique device identification numbers;
- Device event information (such as crashes, system activity, and hardware settings, browser type, browser language, the date and time of your request and referral URL);
- How your device interacts with Phanoon Limited website and Services, including pages accessed and links clicked;
- Broad geographic location (e.g., country or city-level area); and
- Other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our website via an external link, such as a link appearing on a third-party site.
10. How We Use Your Data
We may use your data for the following purposes:
- Identification and authentication: we may use your data to process your order for delivery and create your account;
- Communicating with you: we may use your data when we communicate with you (e.g., when we respond to customer support or other inquiry);
- Deliver your order: we may use your data to process your purchase for delivery;
- Improving our services: we may use your data to understand how you use our services and how we can improve them. In general, we analyze aggregated data rather than specific user data. We may, however, need to analyse a particular case to address a problem (e.g., a bug that affects only a few accounts);
- Customizing your experience: we may use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying site that you might enjoy, based upon your viewing choices;
- To ensure network and data security: we may process your personal information to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks, and to comply with applicable security laws and regulations. The threat landscape on the internet is continuously evolving, which makes it more critical than ever that we have accurate and up-to-date information about your use of Phanoon Limited Services;
- Marketing and advertising: we may use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you;
- Exercising our rights: where reasonably necessary, we may use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our terms of service;
- Legal compliance: we may use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order;
- Protecting your information: where appropriate, we may anonymize, backup, and delete specific data;
- For research and development: we may process your personal information to understand better the way you use and interact with Phanoon Limited's Services. Also, we use such information to customize and improve Phanoon Limited features and the content and layout of our site and applications, and to develop new services.
We may use algorithms and other automated means to implement any of the above.
11. Remarketing On The Website And Services
12. Google AdWords
13. With Whom We Share Your Data
With your consent, we may share your data with third parties where we have obtained your express permission to do so. You may revoke these consents. We share data with third parties as follows:
- Authorized vendors: we may share your data with third-party vendors that help us operate our website, process payments, and deliver our services and also comply with your instructions and our contractual obligations. These include payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, e-mail service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors;
- Advertising: we may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, e-mail address, or physical address with such persons;
- Analytics: we may share your data with persons who provide analytics showing how customers are using our services; and
- Certain legal obligations: we may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction.
14. Payment Processor
Note your payment card details are not shared with Phanoon Limited by the provider.
15. Do Not Track
Do Not Track ("DNT") is a privacy preference that users can set in specific web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
16. Interest-Based Advertising Technologies
As noted above, you may limit advertisement tracking using advertising identifiers through your device's privacy settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org , and www.aboutads.info.
17. Data Retention
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may keep logs of automatically collected information (for internal analytics) such as your e-mail address, your tax information; communications with you; and your transactional information (for auditing, tax, and commercial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.
If we receive legal process about your account, we will retain your data for as long as we, in good faith, believe it is necessary to comply with the legal process.
18. EEA Data Subjects
Legal Bases for Processing your Information: For individuals who reside in the European Economic Area (Collectively "EEA Residents"), data collected from you may be transferred or processed in the United Kingdom. At the time the data is collected, we rely on legal bases for processing your information under Article 6 of the EU GDPR. We generally only process your data where we are required to, where the processing is necessary to perform any contracts we entered into with you (or to take steps at your request before entering into a contract with you) and for our legitimate interests to operate our business or to protect the Phanoon limited site or your property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
19. Your Privacy Choices
We enable you to make numerous choices about your data:
- You may choose not to provide us with certain information. For example, you may decide not to sign up for our newsletters or not place an order on our website;
- You may opt-out of receiving commercial e-mails from us;
- You may close your account; and
- Depending on the location, users from certain countries may have additional rights.
20. Our COPPA Policy Towards Children
Phanoon Limited complies with both the Children's Online Privacy Protection Act of 1998 (COPPA) and, concerning EU data subjects, with GDPR. We do not knowingly request to collect personal information required for the Phanoon Limited user account from any person under the age of 18. Please notify us if you know of any individuals under the age of 18 using our website so we can take action to prevent access to our Services.
21. Cross-Border Transfers
To facilitate our global operations, Phanoon Limited may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world.
We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Phanoon Limited, you acknowledge and agree to the processing of your personal information in this way. If you have a complaint about our privacy practices and our collection, use, or disclosure of personal information, please submit your request via any of Phanoon Limited provided Contact Us mediums.
22. Data Transferred Out Of The EU
Phanoon Limited is the publisher of the website and confirms its compliance with the EU-US Privacy Shield Framework. We are committed to subjecting all personal information received from the European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List at www.privacyshield.gov.
Phanoon Limited does its best to process personal information it receives under the standards of Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf before we share your information with any third party. Phanoon Limited will enter into a written agreement that the third party provides at least the same level of privacy safeguard as required under those Frameworks, and assures the same level of protection for the personal information as required under applicable data protection laws.
Worldwide data subjects with inquiries or complaints relating to Phanoon Limited Privacy Shield internal policy should first contact Phanoon Limited by filling the CONTACT US form provided in www.Phanoon.com. If we are unable to resolve your complaint or dispute, you may refer your complaint to our designated independent dispute resolution mechanism, i.e., the International Centre for Dispute Resolution ("ICDR").
23. Privacy Shield
24. Legal Bases For Processing (For EEA Users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the services, including to process your orders, provide customer support and personalized features and to protect the safety and security of the services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because a third party (e.g. your employer) or we have a legitimate interest to do so, you have the right to object to that use however, in some cases, this may mean no longer using the services.
25. Security Measures For Safeguarding Your Information
Phanoon Limited takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of personal information. These include, but are not limited to, internal reviews of (a) Phanoon Limited's data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Phanoon Limited stores personal information.
26. Third-Party Site And Links
Phanoon Limited’s content may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Phanoon Limited may use third parties to provide components of the Phanoon Limited content. In either case, such third parties may have separate privacy policies and data collection practices, independent of Phanoon Limited. Phanoon Limited: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such site, and (c) does not make any warranties or representations about the materials, products or services offered on such website or the security of any information you provide to them.
27. California / Delaware Do Not Track Disclosures
Various third parties have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer's online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Phanoon Limited do not monitor or take any action concerning these signals or other mechanisms.
28. E-mails Communications
By creating an account, you consent to receive commercial e-mails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt-out or opt-in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process, and you will continue to receive transactional e-mails from us (e.g., e-mails confirming transactions or providing information about your account).
29. Data Security
We are committed to maintaining the security of your data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available. Our data centers and those of our partners utilize new physical security measures to prevent unauthorized access to the facility. Also, all personal data is protected in a location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry-standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
30. GDPR Statement For (EEA Users)
These apply only to natural persons residing in the European Economic Area (for this section only, "you" or "you're" shall be limited accordingly). It is Phanoon Limited's policy to comply with the EU's General Data Protection Regulation (GDPR). Following the GDPR, we may transfer your personal information from your home country to the United States (or other countries) based upon the following legal frameworks:
- Legitimate business interests: We could not provide our services or comply with our obligations to you without transferring your personal information to the United States;
- Consent: We may transfer your personal information when we receive your express, revocable consent;
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfill our obligations in response to direct requests. We will endeavor to process applications within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they impose an unreasonable cost on us.
If you have a request, complaint, or inquiry, please contact our data protection officer at email@example.com. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
31. GDPR Data Privacy User Rights
If you are an EU resident and Phanoon Limited is processing or transmitting your data, then you, as an "EU data subject", benefit from the following rights and privileges under the GDPR:
- Right of Access;
- Right to rectification;
- Right to erase your data;
- Right to Data Portability;
- Right to Restrict the Processing of your data; and
- Right to Object.
32. Your Right To Withdraw Consent
You have the right to withdraw your consent without detriment at any time by contacting us at firstname.lastname@example.org. You can also change your marketing preferences. If we do not satisfactorily resolve your request or concern, you may contact our data protection officer; their e-mail is email@example.com.
33. Opting Out Of Messages From Us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message sent to you (found at the bottom of the e-mail) or send an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt
34. Opting Out Of Sharing With Third Parties For Marketing
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an e-mail to email@example.com. Please note that if you will opt-out in this manner, certain aspects of the website and platform may no longer be available to you. We will process your request within a reasonable time after receipt.
35. Opting Out Of Interest-Based Advertising
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from individual data partners and other advertising partners that participate in self-regulatory programs. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance and the European Interactive Digital Advertising Alliance.
36. Security And Personal Information
The Phanoon Limited site uses the best methods to store and secure all Personal Information on servers with restricted access and electronic security technologies. Notwithstanding the preceding, the website cannot guarantee that such precautions would render the site and its servers immune to security breaches.
37. Terms and Conditions
To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website.
39. Contact Us