Privacy Policy

Protecting personal information stored in the services provided by Phoenix Technology Group LLC (the “Phoenix,” “we,” “us,” or “our”) are core Phoenix values. This Privacy Policy describes how Phoenix collects, uses, and shares personal information you provide to us in order to access the services on websites and applications controlled by Phoenix (the “Services”). This Privacy Policy describes the choices available regarding Phoenix’s use of your personal information, the steps you can take to access this information, and how to request that we correct or delete it. This Privacy Policy does not apply to Services that do not link to this Privacy Policy or to third-party websites to which Phoenix may link

HOW WE COLLECT PERSONAL INFORMATION

Phoenix collects personal information in the course of providing the Services. Personal information means information that is related to an individual. Personal information includes both information provided by users of the Services, as well as the information we collect and process in the performance of our duties under the Agreement. Personal information is collected when you establish an account through the Services, or when you communicate with Phoenix about the Services. We may also collect personal information that is necessary for our legitimate interests, which will be disclosed to you at the time of collection. Phoenix will use this information for the purposes of which it was collected and as disclosed in this Privacy Policy.

We receive and store certain types of information from you every time you use the Services. For example, we may automatically log your browser type, language preference, the date and time of your visit to the Services, your Internet Protocol (IP) address, and the website you visited. In addition, we receive and store information about your use and activity within our Services.

  • Cookies. We may automatically collect information using “cookies.” Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Services and improve your experience within our Services. You can set your browser to not accept cookies, but that may prevent us from providing you with the full range of Services we offer. Also, please be aware that if you visit other websites you may be required to accept cookies. The use of cookies by third parties is not covered by our Privacy Policy. We do not have access or control over these cookies.
  • Web Beacons. We may collect information using web beacons. Web beacons are electronic images that may be used through our Services or in our emails. We use web beacos to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
  • Other. We may also use clear gifs or other data files or identifiers to collect information for statistical purposes and to improve and develop the Services we provide. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.

Upon your request or with your consent, your healthcare provider may share information about you, including your personal information, with Phoenix. Phoenix shall only use such information in accordance with any instructions or restrictions provided to Phoenix by your healthcare provider. With regard to such information, Phoenix shall comply with the applicable provisions of Health Insurance Portability and Accountability Act and the regulations promulgated thereunder, and the Health Information Technology for Economic and Clinical Health Act and any regulations promulgated thereunder, to the extent such privacy laws are applicable to Phoenix as a “business associate” of a “covered entity.”

HOW WE USE PERSONAL INFORMATION

Phoenix uses the personal information collected through the Services to improve the Services, communicate with users, and personalize and improve the Services. Additionally, Phoenix may use personal information to:

  • Respond to user service requests.
  • Administer user accounts.
  • Provide other products and services to our customers, which may include healthcare providers.
  • Respond to user questions and concerns.
  • To administer fees and provide invoices or resolve billing issues.
  • Conduct research and analysis.
  • To fulfil our contractual obligations.
  • Other legitimate purposes permitted by applicable law.

HOW WE SHARE PERSONAL INFORMATION

Phoenix will only disclose your personal information in the following situations:

  • As required by law such as to comply with a subpoena, or similar legal process.
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a written government request.
  • If Phoenix becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, you agree that Phoenix may transfer personal information to a third party as part of that transaction.
  • To any other third party with your prior consent to do so.
  • To service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law.
  • To the extent you are made aware of or direct such disclosure, Phoenix may disclose personal information to Phoenix’s other customers associated with you, which may include healthcare providers associated with your medical care.

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not otherwise sell your personal information to third parties.

ACCESSING AND UPDATING PERSONAL INFORMATION

To review and update personal information to ensure it is accurate, contact us, or use our online tools available through your account. To the extent that you cannot access or correct the personal information in your account, Phoenix will make commercially reasonable efforts to provide reasonable access to any personal information we maintain within 30 days of an access request. We provide this access so you can review your personal information, make corrections, or request deletion. When updating your personal information, we may ask you to verify your identity before we can act on your request. If we cannot honor your request within the 30-day period, we will tell you when we will provide access. In the unlikely event that we cannot provide you access, we will explain why. You may also unsubscribe from promotion emails sent by the Phoenix. To do so, please follow the instructions in any email you receive from us. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, or to ask you to rate a product or service you have purchased. If you request your personal information be updated or if you unsubscribe from communications, we may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations.

SECURITY

Providing security for the information entered into Phoenix’s Services is of paramount importance to Phoenix. We take appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction, of personal information. However, please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure and we do not guarantee its absolute security.

RETENTION OF PERSONAL INFORMATION

Phoenix retains your personal information:

  • For so long as your account is active or as needed to provide you with products or services or to fulfil our contractual obligations.
  • As necessary to comply with applicable legal obligations, resolve disputes, and enforce our legal rights.
  • For so long as is necessary for the purposes for which we collected such personal information.

LINKS TO OTHER WEB SITES

Our Services may include links to other websites. If you submit personal information to any of those sites, your information is subject to their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 provides California residents with certain additional rights as it relates to their personal information. It provides that a business, such as Phoenix, must provide a California resident with a means of requesting certain information regarding the business’s disclosure of the California resident’s personal information to third parties for the third party’s direct marketing purposes. However, as discussed in our Privacy Policy, we do not provide your personal information to third parties for their direct marketing purposes.

EUROPEAN ECONOMIC AREA VISITORS

In accordance with applicable laws, you may have the right to request access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. Where you believe that we have not processed your personal information in accordance with applicable laws, you may lodge a complaint with the respective supervisory authority or data protection regulator. The provision of personal information by you will be for contractual, marketing, analytical purposes, or other purposes as referred to in this Privacy Policy. When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

Under European data protection laws, Phoenix must have a legal basis to process personal information. The legal basis that applies in a particular instance will depend on the specific purpose, as described above, for which Phoenix is processing personal information:

  • In certain cases, Phoenix may ask for your consent to collect and process your personal information. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “Contact Information” section. Please note that the withdrawal of consent will not affect processing which has already occurred.
  • In other instances, the processing of your personal information may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
  • In still other instances, Phoenix may process your personal information based on Phoenix’s legitimate interests in communicating with you about our products and services, and about scientific research and educational opportunities. You have the right to opt-out of all such processing of your personal information. You may do so by contacting us as described in the “Contact Information” section.

INTERNATIONAL OPERATIONS

Phoenix is based, and this site is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth in this Privacy Policy. Where we transfer your personal information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection to receive personal information, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses by emailing us at privacy@phoenixtech.com.

CONTACT INFORMATION

Phoenix welcomes your comments or questions regarding this Privacy Policy. If you have questions about this Privacy Policy or want to contact us regarding how we handle your data, please email privacy@phoenixtech.com or write to Phoenix Technology Group, LLC, Attn: Legal Department, 6630 Owens Drive, Pleasanton, CA 94588.

If Phoenix needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.

CHANGES TO THIS PRIVACY POLICY

Please note that we may change this Privacy Policy from time to time. If we change this Privacy Policy in ways that affect how we use your personal information, we will update the last revision date below. We will also post an updated copy of this Privacy Policy in a clear and conspicuous location in our Services or on our home page. Your continued use of the Services will be deemed your agreement that your personal information (including information collected in the past) may be used in accordance with the new policy. If you do not agree to the changes, then you should stop using the Services, and notify us that you do not want your personal information to be used in accordance with the changes.

(Date of last revision: August 1, 2019)