Privacy Statement.

Effective Date: February 28, 2024.  

Phaedon Website Privacy Policy

Welcome! You have arrived at www.phaedon.com, which is owned and operated by Phaedon, LLC (“Phaedon”).  Throughout this Privacy Policy the words “we”, “us” and “our” refer to Phaedon, and the words “you” and “your” refer to the user visiting www.wearephaedon.com, including any associated mobile application (collectively the “Site”).  This Privacy Policy applies to information that we collect at the Site (including any mobile version) and our handling of such information.  This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Site (unless otherwise stated below).  Please review the Site’s Terms of Use, which govern your use of the Site. 

By accessing and using our Site, you consent to our Privacy Policy, our Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.   

1. What Information Does the Site Collect?  

1. 1. Information You Provide to Us

Personal Information.  We may ask you to provide us with, or you might submit via the Site, personally identifiable information, which is information that identifies an individual personally.  This might include your first and last name, telephone number, e-mail address and street address (“Personal Information”).  We may collect this Personal Information through various forms and in various places on the Site, including account registration forms, “contact us forms,” employment inquiry forms, or when you otherwise upload data to and interact with the Site. 

(b) Information Collected or Stored As You Access and Use the Site 

In addition to any Personal Information or other information that you choose to submit to us via the Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”).  This Usage Information includes Personal Information and may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site.  To the extent we associate Usage Information with Personal Information we collect directly from you on the Site, we will treat it as Personal Information.  

This Usage Information may include:

• your IP address, UDID or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
• your Device functionality (including browser, operating system, hardware, mobile network information);
• the URL that referred you to our Site;
• the areas within our Site that you visit and your activities there, including remembering you and your preferences;
• your Device location;
• your Device characteristics; and
• certain other Device data, including the time of day, among other information.  

Tracking Technologies.  We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies.  A cookie is a data file placed on a Device when it is used to visit the Site.  A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device.  HTML5 cookies can be programmed through HTML5 local storage.

Web Beacons.  Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon.  Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.  

Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.  The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.  

Browser Fingerprinting.  Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.  

ETag, or Entity Tag.  A feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.  If the resource content at that URL ever changes, a new and different ETag is assigned.  Used in this manner ETags are a form of Device Identifier.  ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.  

Recognition Technologies.  Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Tracking Technologies Usage.  We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity and improve security.  

PerformanceRelated.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content or products offered through the Site.  

FunctionalityRelated.  We may use cookies or other Tracking Technologies that are useful to offer you enhanced functionality when accessing the Site, including identifying you when you signin to our Site or keeping track of your specified preferences, including in terms of the presentation of content on our Site.  

TargetingRelated.  We may use Tracking Technologies to deliver content relevant to your interests on our Site and thirdparty sites based on how you interact with our content.  This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you. 

Users who do not wish to use browser cookies can set up their browser so that the storage of cookies is not accepted. Please note that in this case, use of the Site may be restricted or unavailable.

Google Analytics. The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google,” www.google.com), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses “cookies,” which are text files placed on a user’s computer to help the Website analyze how users interact with the sites. The information generated by the cookies will be transmitted to and stored by Google on servers in the United States.

Google normally anonymizes IP addresses, and only rarely transfers the whole IP address from outside the US to a Google server in the US. In those cases, the IP addresses are shortened upon arrival on Google’s servers. Google uses this information on behalf of Phaedon in order to evaluate use of the Site, compile reports on website activity for website operators and provide them other services relating to website activity and internet usage. The IP address that a browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that doing so may limit the Website’s functionality.

Google may also transfer this information to third parties if required to do so by law, or where third parties process the information on Google’s behalf.

For further information please visit: http://www.google.com/analytics/terms/gb.html.

By using Google Analytics, Phaedon aims to provide a faster and more stable service on the Site. Google Analytics allows Phaedon to optimize the loading times of the Site and better understand how users interact with them. Phaedon’s legitimate interest in doing so is to allow improvements to the Site’s performance and to enhance Phaedon’s services for visitors to the Site.

Use of the Site is considered consent to Google processing data in the manner and for the purposes set out in this policy.

Users can also opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for their current web browser. This places an opt-out cookie, which prevents the future collection of data when visiting Phaedon’s (or another) Site. Deactivating individual tracking services (e.g. by setting an opt-out cookie) will impact all affected tracking tags that are part of Google Analytics. Please be aware that opting out may cause some of the Site’s features to be unavailable. 

For representative examples of the cookies Phaedon uses, refer to the following table:

What Choices Do Website Visitors Have?

Users can always choose not to input their information, even though it might be needed to access information about Phaedon’s services.

Users can set browsers to block cookies or erase Phaedon’s cookies from their computer, though doing so may prevent some aspects of the Site from working properly.

Most browsers provide the ability for people to manage cookies to meet their needs. In some browsers, users can set up rules to control cookies on a site-by-site basis, giving users granular control over their privacy. These features enable users to disallow cookies from all sites except the trusted sites. 

Please see the list below for browser manufacturers’ help pages that relate to cookie management:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser

For other browsers, please consult the documentation that your browser manufacturer provides.

Users can prevent data collection by Google Analytics by clicking on the following link: https://tools.google.com/dlpage/gaoptout. This will place an opt-out cookie, which prevents the future collection of data when visiting Phaedon’s (or another) Site. This opt-out cookie must be stored permanently on a user’s computer. If a user deletes this opt-out cookie or it is deleted automatically via browser settings, the user will have to install this opt-out cookie again when visiting Phaedon’s Site in the future.

Tracking Technologies Choices and Consent.

We obtain your consent to our information storage or collection Tracking Technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies as set forth above.  Please note that we are not required to obtain your consent to the information collection Tracking Technologies identified above that are strictly necessary.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

Third Party Tracking and “Do Not Track.”

Please note that the Site does not collect Personal Information about your online activities over time or across third party websites or online services. Therefore, “do not track” signals broadcasted from web browsers do not apply.

 (c) Information Third Parties Provide About You

We may, from time to time, supplement the information we collect directly from you on the Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with your Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.  In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.  

 (d) Interactions with Third-Party Sites 

The Site may include functionality that allows certain kinds of interactions between the Site and a third-party website or application.  The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us.  For example, when you register with the Site, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Site, or otherwise link accounts.  If we offer and you choose to use this functionality to access or use our Site, the third-party site or application may send Personal Information about you to us.  If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Site. In addition, we may provide third-party sites’ interfaces or links on the Site to facilitate your sending a communication from the Site.  For example, we may use third parties to facilitate emails, tweets or Facebook postings.  

The Site may also include links to third-party websites for purposes of submitting a job application or making a job inquiry.  Those websites might require your entering certain Personal Information that may be shared with Phaedon. 

These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy.  Phaedon may not control or have access to your communications through these third parties.  Further, when you use third-party websites or services, you are using their services and not our Site and they, not we, are responsible for their practices.  You should review the applicable third-party privacy policies before using such third-party tools on our Site. 

2. How Do We Use the Information Collected?

Generally.  We may use your Personal Information or Usage Information that we collect about you:  (1) to provide you with information that you have requested or agreed to receive, including for job opportunity consideration as a result of an online employment application or for providing general information about Phaedon’s services in response to a request submitted online; (2) to provide you with information via email about new Phaedon product offerings on an ongoing basis, unless you opt out of receiving such emails; (3) to enable you to participate in a variety of the Site’s features; (4) to send promotional or marketing emails to you on behalf of other businesses or organizations; (5) to process your account inquiry, including verifying your information is active and valid; (6) to improve the Site, to create new service offerings, to customize your experience on the Site, or to serve you specific content that is most relevant to you; (7) to contact you with regard to your use of any of the Site and, in our discretion, changes to the Site and/or any of the Site’s policies; (8) for internal business purposes; and (9) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy. 

Contact Us.  Please note that information submitted to the Site via a “contact us” or other similar customer inquiry function may not receive a response.  

3. How and When Do We Share Information with Third Parties?

Phaedon may share your Personal Information with third parties for their direct marketing purposes.  We also may share non-Personal Information, such as aggregated user statistics and browsing behavior information, with third parties.  We may share the information we have collected, including Personal Information, as disclosed at the time you provide the information and as described below or otherwise in this Privacy Policy.  Phaedon may also disclose Personal Information as follows:

(a) When You Request Information from or Provide Information to Third Parties.  You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.  

(b) Third Parties Providing Services on Our Behalf.  We may use third-party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you special offers or perform other administrative services.  We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.  Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to Personal Information.  We are not responsible for those third-party technologies or activities arising out of them, nor are we responsible for the effectiveness of or compliance with any third party’s opt-out options.   

(c) To Protect the Rights of Phaedon and Others.  To the fullest extent permitted by applicable law, we may also disclose Personal Information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Phaedon or third parties (including through the enforcement of this Privacy Policy, our Terms of Use, the Terms of Sale or other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders).  To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.    

(d) Affiliates and Business Transfer.  We may share Personal Information with our parent, subsidiaries and affiliates.  We also reserve the right to disclose and transfer all collected Personal Information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.  

4. Does Third-Party Content or Links to Third-Party Sites Appear on the Site?

The Site may contain content that is supplied by a third party, such as YouTube, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you.  In addition, when you are on the Site you may be directed to other services that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others.  For example, if you “click” on a link, the “click” may take you off the Site onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies.  We encourage you to note when you leave our Site and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.  

5. How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes by contacting us.  If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for Phaedon’s administrative purposes.  You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your Site account and changing your communication preferences.  This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Attention: Privacy Officer, Phaedon, LLC, 420 N. 5th Street; Suite 1000, Minneapolis, MN 55402; By e-mail: privacy@phaedon.com.  

6. What About Transfer of Information to the United States?

Our Site is operated in the United States.  If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.  By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.  

7. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world.  We do not use the Site to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent.  

In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations.  If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at privacy@phaedon.com.  

8. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit [link to specific privacy notice for California residents]. 

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state.  To exercise any of these rights or to appeal any decision that we have made about our compliance with a request, please contact us at privacy@phaedon.com. 

9. What About Security?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure Personal Information.  However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure.  Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.  

10. What About Changes to the Privacy Policy?

We reserve the right to change this Privacy Policy at any time.  Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Site indicates your consent to the privacy policy posted at the time of use.  However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent.  To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

6442309.5

Phaedon Privacy Policy for California Residents

Effective Date: 

Last Updated on: 

This Privacy Policy for California Residents supplements the information contained in Phaedon, LLC’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. 

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements.

Information We Collect

We collect 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, household, or device (“personal information“). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has/we have collected the following categories of personal information from consumers within the last twelve (12) months: 

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. 
• Indirectly from you. For example, from observing your actions on our platform and App.
• From third parties.

Use of Personal Information

We may use, share or otherwise disclose the personal information we collect for one or more of the following purposes: 

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns. 
• To provide, support, personalize, and develop the Phaedon Website and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not and will not share your personal information with third parties for their marketing purposes. In the preceding twelve (12) months, Company has not sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
• The specific pieces of personal information we collected about you (also called a data portability request).

 We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. 

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing Phaedon at privacy@wearephaedon.com.  

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. 

You may also make a request to know or delete on behalf of your child by emailing Phaedon at privacy@wearephaedon.com. 

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative as requested by Phaedon;
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. 

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. 

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact Phaedon at privacy@wearephaedon.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. 

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your 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 your request. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our platform and app that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wearephaedon.com or write us at: Privacy Officer, Phaedon, LLC, 420 N. 5th Street; Suite 1000, Minneapolis, MN 55402.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our platform and app following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Phaedon collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 

Website:  www.wearephaedon.com

Email: privacy@wearephaedon.com

Postal Address: 

Phaedon, LLC

Attn: Privacy Officer

305 N. 5th Ave; Suite 200

Minneapolis, MN 55401

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@wearephaedon.com.

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