Phoenix Transformation International LLC - PRIVACY & DATA PROTECTION POLICY

Effective as of March 1, 2025

Phoenix Transformation International LLC (“Phoenix Transformation” or “we”) is committed to protecting the Personal Information of our customers, business partners, and employees. This Privacy & Data Protection Policy (the “Policy”) outlines how we collect, use, share, transmit, maintain, and store (collectively, “process”) information related to an identified or identifiable individual (“Personal Information”), including through third-party service providers, and the rights you have regarding your Personal Information. For the purposes of this Policy, “you” and “your” refer to any individual customer, business partner, employee, or other individual whose Personal Information we process, and “we”, “us”, and “our” refer to Phoenix Transformation.

Personal Information does not include data from which the identity of the individual has been removed (anonymous data).

This Policy applies to information stored electronically or in hardcopy, and to our websites, mobile apps, social media accounts, and other online services that link to this Policy. Our websites may also contain links to other websites. If you follow a link to these websites, please review their own privacy notices.

Please read the following carefully to understand how we collect, use, and protect your Personal Information. If you have any questions or wish to exercise your rights under this Policy, please reach out to us using the contact details in the “How to contact us” section below.

Privacy Principles

Collection, Notice, and Processing of Personal Information
Phoenix Transformation will collect Personal Information only as necessary for the purposes for which it was collected, and will not use it for other purposes unless compatible with the original reason. If necessary, we will inform you about how your Personal Information is processed. We may process your Personal Information without your knowledge or consent where required by law.

Data Security & Confidentiality
We take appropriate security measures to protect your Personal Information from loss, unauthorized access, alteration, and disclosure. Access to your data is restricted to those employees, agents, contractors, and third parties with a legitimate business need, in compliance with applicable law.

Misappropriation of Personal Information
We have procedures in place to manage suspected data breaches and will notify you, as well as any applicable regulatory authority, if a breach occurs where required by law.

Choices Regarding Use and Disclosure of Personal Information
We strive to give you control over the use of your Personal Information, including providing an option to opt out of marketing communications, where required by law.

Accessing and Maintaining Personal Information
Depending on applicable law (e.g., the EU General Data Protection Regulation (“GDPR”)), you may have the right to access, correct, request deletion of, or restrict the use of your Personal Information.

Transferring Personal Information
As a global organization, we may transfer your Personal Information to countries outside of your country of residence, including those that may not have the same level of data protection laws. We take steps to ensure such transfers comply with applicable laws.

What Information Do We Collect About You?

Information You Provide
We collect information when you voluntarily provide it to us, including when you interact with us via phone, email, social media, websites, apps, or when you contract for services. This may include Personal Information such as your name, address, email, phone number, financial information, and other relevant data.

Cookies, Web Beacons, and Website Usage
Our websites use cookies, web beacons, and log files to improve the functionality and content of our websites. These technologies may help us tailor content and analyze traffic. You can manage your cookie preferences through your browser settings.

Information from Other Sources
We may obtain Personal Information about you from third parties, such as business partners or service providers.

Child Online Privacy Protection Act (COPPA) Compliance
We do not knowingly collect Personal Information from children under the age of 18. If you are under 18 and have provided us with Personal Information, please contact us to have it removed.

How Do We Use Your Information?

We use your Personal Information to:

  • Provide services or information you request.

  • Process orders and manage contracts.

  • Communicate with you, including sending marketing communications (where permitted).

  • Comply with legal obligations and protect our rights.

We will retain your Personal Information for as long as necessary to fulfill these purposes or as required by law.

How Do We Share Your Information?

We may share your Personal Information with:

  • Service providers who process data on our behalf.

  • Third parties in the event of a business transition, such as a merger or sale.

  • Law enforcement or regulatory bodies if required by law.

Links to Non-Phoenix Transformation Websites & Third-Party Applications

Our websites may contain links to external sites. We are not responsible for the privacy practices or content of these external sites, and you should review their privacy notices.

Potential Rights Under the GDPR

If you are a resident or citizen of the European Economic Area (EEA) or Switzerland, you may have the following rights under the GDPR:

  • Right to access your Personal Information.

  • Right to correct or update your Personal Information.

  • Right to request deletion of your Personal Information.

  • Right to restrict or object to the processing of your data.

  • Right to data portability.

  • Right to withdraw consent at any time, if applicable.

Potential Rights Under the CCPA and CPRA

If you are a resident of California, you may have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to know what Personal Information we have collected.

  • Right to request deletion of your Personal Information.

  • Right to opt-out of the sale of your Personal Information.

  • Right to non-discrimination for exercising your rights under these laws.

Updates to Our Privacy Policy

We may update this Policy periodically to reflect changes in our practices. Any updates will be posted on our website, and where appropriate, we may notify you by email.

How to Contact Us

If you have any questions or concerns regarding this Privacy & Data Protection Policy or wish to exercise your rights, please contact us at: Email: info@phoenix-transformation.org

By using our services, you acknowledge that you have read and understand this Policy.