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Phaedon Privacy Policy
Last Updated: September 25, 2025
Phaedon, LLC (“Phaedon,” “we” or “us”) respects privacy and is committed to protecting personal information. This Privacy Policy (the “Policy”) explains our practices for handling information we may collect and use about website visitors, prospective clients or partners, and others with whom we interact in making our website at wearephaedon.com available (the “Website”). This Policy describes the types of personal information we may receive, how we may use and disclose the information, and certain rights and options individuals may have regarding their information.
By providing us with personal information or using the Website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Website or provide us with your information.
Important Information About This Policy
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.
To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly.
We provide software and other services to companies who are our clients. If you have questions about how a specific business who uses one of our solutions collects and processes your personal information, please contact such business with which you have a relationship directly. This Policy does not apply to our customers’ end users or loyalty members.
Personal Information We Receive or Collect About You
For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. Our services are directed to business professionals and owners and, as a result, the personal information we collect is often the personal information of consumers acting in a commercial context.
A. Information You Provide
Personal Information we collect from you can be categorized as follows:
We collect this information when you visit or navigate our Website, fill in forms on through use of our Website, submit applications or inquiries to us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources and information about you that is publicly available.
B. Automatically Collected Usage and Device Information
Like most website operators, we use various technologies to automatically collect information about visitors. Those technologies include:
These technologies can be separated into the following categories:
The above technologies could be first-party technologies, meaning that they are set and controlled by us, or they could be third-party technologies, that are controlled or managed by third-party vendors or partners.
For representative examples of the cookies Phaedon uses, refer to the following table:
C. Information from Other Sources
We may obtain both personal and non-personal information about you from our vendors, affiliates, business partners, contractors, suppliers, and other third parties and add it to other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across our Website, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
D. Social Media
If you interact with us on any social media platform (e.g., Meta, X, LinkedIn), depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy. In addition, where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
How We Use Personal Information
We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.
Our Marketing Efforts
We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.
Disclosure of Personal Information
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.
In addition, we may disclose your personal information to the following types of third parties:
We further reserve the right to refer or disclose your information to law enforcement or regulatory authorities in the event that we believe you, other individuals, our partners or service providers, or anyone else is in danger, at risk of harm, in violation of applicable laws, or representing a safety concern.
Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
Your Choices About Personal Information
We respect your right to make choices about the ways we collect, use, and disclose your information. We try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following.
In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.
Additional Information for California Residents
This section of our Policy applies solely to “consumers” as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), and describes our activities when we are acting as a business, as defined by the CCPA.
CALIFORNIA NOTICE AT COLLECTION
In simply accessing one of our digital properties, the following applies. If you create an account or interact with us in other ways (e.g., by filling out forms on our Website), please continue reading below to learn more about the personal information we collect, and how we use and disclose such information.
*No sensitive personal information is collected
**None of this personal information is “sold” or “shared,” as those terms are defined by the CCPA.
· Internet activity, such as browsing details, search details, information about your interaction with the website, application, or advertisement, including page views, clicking tendencies, and time spent on a page, and other similar event or session data
· Engaging in analytics regarding use of our digital properties by users for the purposes of marketing to current or potential customers.
· Developing, updating, and improving our services, including our Website
· To help maintain the safety, security, and integrity of our Website
· Preventing and detecting fraud, hacking activities, security breaches, and other unlawful activities in connection with our website and mobile applications
· Enforcing our agreements and complying with our legal or regulatory obligations
CALIFORNIA PRIVACY POLICY
To learn more about our practices in connection with the collection, processing, and disclosure of personal information relating to California consumers, continue to read below.
A. Personal Information We Collect and Disclose
As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For the purposes of the CCPA and this section, personal information does not include certain regulated information, such as protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act, or public information.
In the past 12 months, Phaedon has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.
· Analytics and marketing/advertising vendors and service providers
· Financial institutions and payment processors
· Professional advisors (accountants, lawyers, and auditors)
· Online analytics and marketing/advertising service providers
From time to time, Phaedon may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.
B. Applicable Retention Periods
For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this section. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.
C. Categories of Sources of Personal Information
Phaedon collects these categories of personal information from the following categories of sources:
D. Business or Commercial Purposes for Collecting and Disclosing Personal Information
We collect and disclose the personal information described above for the following business or commercial purposes:
E. Sensitive Personal Information
Phaedon does not use or disclose “sensitive personal information” (as defined by the CCPA) for the purposes of inferring any characteristics of any individual. As a result, we treat all such information as “personal information,” for the purposes of our obligations under the CCPA.
F. Sale or Sharing of Personal Information
In the past 12 months, Phaedon has not “sold” or “shared” (as those terms are defined by the CCPA) any personal information of any California resident. Phaedon does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.
G. Your Rights Under the CCPA
Subject to exceptions, the CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.
As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
H. Exercising Your Right to Know, Request Deletion, or Correct Inaccurate Information
To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: privacy@wearephaedon.com with the subject line: “CCPA Request”. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:
As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.
You may only make a verifiable consumer request to know twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.
The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
J. Our Commitment Not to Discriminate
Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:
K. Data Disclosures for Direct Marketing Purposes
California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.
Additional Information for EEA, UK, and Swiss Residents
The European Union’s General Data Protection Regulation and the United Kingdom’s and Switzerland’s versions of the same (collectively, referred to as the “GDPR”) afford certain rights to individuals in the European Economic Area or Switzerland, Gibraltar, United Kingdom and similar, as applicable (collectively, referred to as “Europe”). If you are in Europe, you have the following rights. Note, however, that not all rights apply in all circumstances.
With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to the email address below with the subject line, “GDPR Request.” This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity. If you are located in Europe and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in your jurisdiction of residence.
We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information. If the lawful basis is your consent, you have the right to withdraw your consent. Please note, we do not engage in automated decision-making.
· Transactional Information
· Communication Information
· Necessary for performance of a contract
· Necessary to comply with legal obligations
· With your consent
If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal information protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.
Data Retention
We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.
Data Location
You understand and agree that information about you may be stored or processed by information technology systems located in the United States or jurisdictions that may have laws that differ from the laws of your country of residence or the jurisdiction in which you reside.
Links to Third-Party Websites
Our website may contain links to third-party websites, including the websites of vendors we use to process information on our behalf. Such websites have separate privacy policies that you should review. We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.
Children’s Privacy
Our Website is intended for a general audience and is not directed at, or intended for use by, children under the age of 13 years. Accordingly, we do not knowingly collect personal information from children under age 13. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.
Changes to this Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of our Website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
How to Contact Us
For questions or more information about our privacy practices, please contact us by using the contact information provided below:
Email: privacy@wearephaedon.com
Postal Address:
Phaedon, LLC
Attn: Privacy Officer
305 N. 5th Ave; Suite 200
Minneapolis, MN 55401
