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Privacy Policy

LAST UPDATED: 15.05.2023

CCPA Notice at Collection: At or before the time of collection, you may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared , and how long such information is retained. You can find those details in this statement below.

Protecting your privacy is really important to us. With this in mind, we’re providing this Privacy Policy to explain how Phoenix Labs, Inc., its subsidiaries, and its affiliates (“Phoenix Labs”, “we”, “us”, or “our”) collects, uses, processes, and discloses your personal information and to help you understand your privacy rights. This Privacy Policy applies to personal information processed by us, including on our websites, games (each the “Game”), related software, websites, and forums, as well as other online and offline offerings. To make this Privacy Policy easier to read, our offerings are collectively called the “Services.” 

The Services may contain links to other websites, applications, or services, and other websites, applications, or services may reference or link to our Services. This Privacy Policy does not apply to any third-party websites, services, or applications (“third-party services”), even if they are accessible through our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each third-party services with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of third-party services. Providing personal information to third-party services is at your own risk. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

REVISIONS TO THIS PRIVACY POLICY

Any personal information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

COLLECTION AND USE OF INFORMATION – WHAT WE COLLECT AND HOW WE USE IT

We collect your personal information in the following ways:

INFORMATION YOU PROVIDE DIRECTLY TO US OR WE COLLECT FROM OTHER SOURCES

Third-Party Application Information. If you access (or download) our Services through a third-party application, platform, or store, such as including but not limited to, the Nintendo eShop, the Steam game platform, the Epic Games platform, Microsoft Store, PlayStation Store, Google Play Store or Apple App Store (each, an “App Store”), a third-party login service, or a social networking site (collectively “Third-Party Platforms”), we may collect information about you from that third-party application that you have made available via your account settings. This may include your third-party application username and email address. In addition, we may collect information that other people provide about you when they use our Services, such as abuse reports or similar information.

Account Information. If you create an account directly with the Services (“Account”), including in-Game account, we’ll collect information that we associate with your Account, including your username, email address, and/or date of birth. If applicable, your Account is separate from any account you may have with any Third-Party Platform’s account. This Privacy Policy does not apply to any of the personal information that may be collected and processed by Third-Party Platforms.  All Third-Party Platforms’ respective privacy policies govern their collection and use of their platform’s account related data. Any questions or requests relating to Third-Party Platform’s account data should be directed to the relevant Third-Party Platform.

Your Communication with Us. We may collect personal information, such as email address, phone number, or mailing address when you ask for information about the Services or notification as to when certain Services will be available, register for our newsletter or loyalty program, apply for a job, or otherwise communicate with us. 

Customer Service. If you contact customer or technical support service, we may use the information you provide to us to look up your information in the relevant customer service database and fulfill your request.

Posting on the Services. We, and others who use our Services, may collect personal information that you submit or make available through our interactive features such as messaging and chat features, commenting functionalities, social media pages, publicly accessible forums, or blogs where you may post content. You should be aware that, when you disclose information about yourself using the public sharing features of the Services (referred to herein as “User Content”), all such content will be considered public, unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Phoenix Labs and other individuals who use our Services may collect the information you submit or make available through these interactive features.

Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information that may include personal information. We may use such information to improve our Sites and/or Services.

Transaction Information. When making purchases through the Services, our third-party payment processor will collect personal information such as your name, postal address, country, phone number, and credit card number. We do not directly collect or store any payment card information entered through our Services, and our payment processor will not share this information with us.

Registration for Sweepstakes or Contests. Occasionally, we may run sweepstakes and contests in which we ask participants to provide contact information (e.g., an email address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing, and business purposes. In some jurisdictions we are required to publicly share information of sweepstakes and contest winners.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events. 

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

INFORMATION WE AUTOMATICALLY COLLECT

Information Related to Use of the Services. We may automatically collect certain information when you use our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, device identifiers, MAC address, cookie identifiers, location information (including inferred location based off your IP address), assumed language, Internet service provider, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on, your progress and activities in our Games, and other statistics. 

Game Play Data. We automatically collect and store Users’ Game play history and their progression through the games we offer. We use this data to administer, improve, and provide the Services to Users.

Cheat Data. We and our third-party service providers may collect, analyze, and publish information about your Game play and your device to detect and deter cheating.

Crash Reports. If you send them, we, or our service providers, may also receive crash reports with more detailed diagnostic information about your device and the activities that led to the crash.

Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we, as well as third parties that provide content, advertising, or other functionality on our Service, may use automated data collection tools such as Cookies, Web Beacons, and other similar technologies (“Technologies”) to collect certain information. The use of such Technologies is subject to your consent.

  • “Cookies” are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies (including the use of Google Analytics Cookies) to monitor usage and web traffic routing on our Services, and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept certain types of Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
  • “Web Beacons” (also known as Web bugs, pixel tags, including third party pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below). For example, we may track your in-Game activity, including recordings of your Game play and other interactions with the Game;
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See “Your Privacy Choices” and “Your Privacy Rights” below to understand your choices regarding these Technologies.

  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. See “Information That We Share With Third Parties” below to learn about the analytics technologies.          

Social Media Platforms. Our Services may contain social media buttons, such as Twitch, Twitter, YouTube, Meta, Reddit, Discord, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide information about your friends through our referral service; third parties may also use these services to upload information about you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship,( e.g., relative, friend, or similar).

HOW WE USE THE INFORMATION WE COLLECT

We, and our service providers, use your information for a variety of business purposes, including:

  • providing and improving our Services (to perform our contract with you) including managing your information and Accounts (if you are an Account holder); providing access to certain areas, functionalities, and features of our Services; answering requests for customer or technical support; corresponding with you regarding the Services and keep you updated on the Services, and policy changes; processing your financial information and other payment methods for products or Services purchased; processing applications if you apply for a job we post on our Services; and allowing you to register for events; 
  • administering your information in our legitimate interest, such as enabling you to enjoy and easily navigate our Services, to pursue our legitimate interests (e.g., direct marketing, research and development including marketing research, network and information security, and fraud prevention), detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; measuring interest and engagement in our Services; using for short-term, transient (e.g., contextual customization of ads); improving, upgrading, or enhancing our Services; developing new products and Services; ensuring internal quality control and safety; authenticating and verifying individual identities, including requests to exercise your rights under this policy; debugging to identify and repair errors with our Services; auditing relating to interactions, transactions, and other compliance activities; sharing information with third parties as needed to provide the Services; enforcing our agreements and policies; and other uses as required to comply with our legal obligations.  
  • using your information for other purposes that are clearly disclosed to you at the time you provide such information or with your consent.
  • Automated Decision Making. We may engage in automated decision making, including profiling, such as to customize your Game experience or match you with other players of a similar skill level. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
  • marketing and advertising our Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us as set forth in “Contact Us” below.

INFORMATION THAT WE SHARE WITH THIRD PARTIES

We may share your information as described in this Privacy Policy, as well as to comply with legal obligations, to protect and defend our rights and property, or with your permission.

Information Shared with Our Services Providers. We may engage third-party services providers to work with us to administer and provide the Services and process payments. These third-party services providers have access to your personal information only for the purpose of performing services on our behalf. The types of service providers to whom we entrust personal information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) customer service activities; (iv) payment processing; and (iv) in connection with the provision of the Services.

Information Shared With Analytics Services. We use Analytics technologies because they allow us to process usage data to better understand how our website and web-related Services are used, and to continually improve and personalize our Services. Some of our analytics partners include:

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” Some of the advertising partners we use include: Snap Inc., Google (DoubleClick), Reddit, TikTok, Twitter, and Facebook.

Business Partners. We may provide your personal information to our business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Affiliates. We may share your personal information with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide.

De-Identified/Aggregated Information Shared with Third Parties. We may use personal information and other data about you to create de-identified and/or aggregated information. For example, we may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used. We may share de-identified and/or aggregated information with third parties for industry research and analysis, demographic profiling, and other similar purposes.

APIs/SDKs. We may use third-party application program interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Information Disclosed in Connection with Business Transactions.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Information Disclosed for Our Protection and the Protection of Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: cooperate with government and law enforcement officials or private parties to: (i) enforce and comply with the law or national security requests; (ii) to respond to claims, legal process (including a court order or subpoena); (iii) to protect our property, rights and safety of the property, rights and safety of a third party or the public in general; (iv) enforce our policies or contracts; (v) collect amounts owed to us and (vi) to stop or assist with an investigation or prosecution of any activity that we consider illegal, unethical, or legally actionable activity.

YOUR PRIVACY CHOICES

We offer you choices regarding the collection, use, and sharing of your personal information and we’ll respect the choices you make. For example, you may have the right to object to certain uses of your personal information. In addition, where you have consented to the processing of your personal information, you may withdraw that consent at any time by contacting us as set forth in “Contact Us” below.

Email Communications and Opt-Out. We may periodically send you free newsletters and emails that directly promote our Services if you sign up to receive these communications. You have the opportunity to “opt-out” (either through your Account or by following the unsubscribe instructions provided in the email you receive) to opt out of receiving future emails. We may continue to send you certain transaction-related communications regarding the Services. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service, this Privacy Policy, information about billing or payment, or customer service.

Cookies and Web Beacons. You may stop or restrict the placement of Cookies, Web Beacons, and other technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android (https://support.google.com/googleplay/android-developer/answer/6048248) and iOS (https://support.apple.com/HT202074).

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy at https://thenai.org/opt-out/, https://youronlinechoices.eu/, https://youradchoices.ca/en/tools. 

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS 

In accordance with applicable law, you may have the right to:

  • Confirm Whether We Are Processing Your Personal Information (the right to know);
  • Access to, and Portability of, Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
  • Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • Request Deletion of your personal information; 
  • Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
  • Request Restriction of, or Object to, our processing of your personal information including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes; 
  • Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and 
  • Appeal our Decision to decline to process your request.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. 

If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents supplements our Privacy Notice and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).  In accordance with applicable law the CCPA provides California residents with the right to know what categories of personal information Phoenix Labs has collected about them, and whether it disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

   

  • We collect some Identifiers such as: name, alias, postal address, phone number, email address, unique personal identifier, online identifier, Internet Protocol address. We may disclose this type of personal information with service providers and advertising partners for our business purpose. 
  • We may collect from job candidates the Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as: a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories. We may disclose this type of information to service providers for our business purposes.  We do not sell or share this type of Personal Information.
  • We may collect from job candidates characteristics of protected classifications under California or federal law such as: 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 familial genetic information]. We may disclose this type of information to service providers for our business purposes.  We do not sell or share this type of Personal Information.
  • We may collect your commercial information such as: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We may disclose this type of information to service providers and advertising partners for our business purposes.  We may sell or share this type of Personal Information with advertising partners for cross context behavioral advertising purposes.
  • We may collect Internet or other electronic network activity such as: browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement. We may disclose this type of information to service providers and advertising partners for our business purposes.  We may sell or share this type of Personal Information with advertising partners for cross context behavioral advertising purposes.
  • We do not collect your geolocation information.
  • We may collect from job candidates their professional or employment-related information such as: current or past job history. We may disclose this type of information to service providers for our business purposes.  We do not sell or share this type of Personal Information
  • We may collect inferences drawn from other personal information to create a profile about a consumer such as: a profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We may disclose this type of information to service providers and advertising partners for our business purposes.  We may sell or share this type of Personal Information with advertising partners for cross context behavioral advertising purposes.

We do not collect any of the following groups of sensitive personal information:

  • Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number.
  • Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. 
  • Personal information that reveals a consumer’s precise geolocation.
  • Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • Personal information that reveals the contents of a consumer’s mail, email, and text messages unless Phoenix Labs is the intended recipient of the communication.
  • Personal information that reveals consumer’s genetic data.
  • Biometric information that is processed for the purpose of uniquely identifying a consumer. 
  • Personal information collected and analyzed concerning a consumer’s health. 
  • Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.  

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in the “Information You Provide Directly to Us or We Collect from Other Sources”, “How We Use the Information We Collect”, and “Information That We Share with Third Parties” sections above, respectively. We will retain personal information in accordance with the time periods set forth in the “Data Retention” section below.

Additional Privacy Rights for California Residents

Opting out of “Sales” of Personal Information and/or of “Sharing” Personal Information for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising”. California residents may exercise their rights at any time by contacting us as set forth in “Contact Us” below.

Disclosure Regarding Individuals Under the Age of 16. Phoenix Labs does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Phoenix Labs does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Non-Discrimination.  If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by the California Consumer Privacy Act.

Authorized Agent.  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child.  To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent and ask us for additional instructions.

Verification.  To protect your privacy, we will take the following steps to verify your identity before fulfilling your request submitted under the CCPA:  when you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the email address or phone number we have associated with you, opening a link sent to the contact information provided and following the instructions on the website you are taken to. 

Notice of Financial Incentive.  As described above in “How We Use the Information We Collect”, we may offer referral programs or other incentivized data collection programs.  For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward or provide personal information about yourself (such as your email address) or regarding your friends (such as their email address) and receive rewards when you or your friends sign up to use our Services.  The referred party may also receive rewards for signing up via your referral.  These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you.  The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a customer and uses our Services, less the expense related to offering those products, services and benefits to program participants.  Said value will be reflected in the incentive offered in connection with each program.

De-Identified Information.  If we create or receive de-identified information, we will not attempt to re-identify such information, except to comply with applicable law.

Accessibility.  This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1.  If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

California Shine the Light.  The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Right for Minors to Remove Posted Content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Services by contacting us as set forth in “Contact Us” below.

SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information.  You can exercise this right by contacting us at privacy@phxlabs.ca with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your Account.  Please note that we do not sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.  If you have any questions, please contact us as set forth in “Contact Us” below.

RESPONDING TO DO NOT TRACK SIGNALS

Do Not Track is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor “Do Not Track” signals or similar mechanisms received from various web browsers.

DATA RETENTION

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

LINKS TO OTHER SITES

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

INTERNATIONAL TRANSFER

All personal information collected via or by Phoenix Labs may be transferred, processed, and stored anywhere in the world, including but not limited to, Canada, the United States, or the European Union, which may have data protection laws that are different from the laws where you live, in the cloud, on our servers, on the servers of our affiliates, or on the servers of our service providers.  For Canada, the files containing your information will be on our servers and those of our service providers and will be accessible to persons that require it for the purposes of their duties. Information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about Phoenix Labs’ policies and practices with respect to service providers outside Canada, please contact us as set forth in “Contact Us” below. We endeavor to safeguard your information consistent with the requirements of applicable laws. 

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.  For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth in “Contact Us” below.

OUR POLICY TOWARD CHILDREN

Our Services are not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information of a child under 13, we will take steps to delete such information from our files as soon as possible.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CONTACT US

If you have any questions or comments about our privacy practices or this privacy policy, please contact us at:

Attn: Privacy Team

Phoenix Labs Inc.

PO Box 21544 RPO Little Italy Vancouver, BC

Canada V5L 5G2

You may also email Phoenix Labs’ Data Protection Officer at privacy@phxlabs.ca

Please include your name, contact information, and the nature of your request so that we can appropriately respond to your communication.