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Phoenix Services LLC is an affiliate of the Apollo funds dedicated to sustainable solutions and maximizing efficiency for the global steel industry with minimal environmental impact, and always with a personal touch.

Downloadable Privacy Policy – Phoenix Services, LLC

 

Privacy Policy

Phoenix Services

 

Last update: November 12, 2021

Phoenix Services LLC and its affiliates and subsidiaries (collectively, “Phoenix” “we” or “us”) respect your (“you”, “your” or “users”) concerns about privacy. This privacy policy (“Privacy Policy”) describes how Phoenix collects and uses information about you, with whom we share it and the choices available to you regarding our use of the information. We also describe measures we take to protect the security of your information and how you can contact us about our privacy practices. Our contact details can be found at the end of this Privacy Policy.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.This Privacy Policy applies for all of our Site visitors. If you are visiting our Site from the EU, Brazil, or California, please find additional Information below.

Information We Obtain

We may obtain information about you in various ways, such as when you:

  • Visit our websites [include website.com names], including mobile website (collectively, the “Site”);
  • Fill out a form on the Site;
  • Sign-up to receive direct marketing communications on the Site;
  • Sign-up to a feature that we offer on the Site and you provide your information in connection with that feature;
  • Attend an event that we or one of our affiliates or partners has organized;
  • Communicate with us (for example, by telephone or by sending us an email);
  • Submit your CV or any other information when applying for a career opportunity through the Site; or
  • Otherwise voluntarily provide us with information about you.

The information we obtain about you may include details such as:

  • personal information / personal data: personally identifiable information, such as name, postal address, telephone number, and email address. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site;
  • business information; such as your company name and your job title;
  • information you submit as a job applicant in connection with a Phoenix career opportunity;
  • technical data: data and information of the access device (e.g. computer, mobile phone, tablet, etc.): that our systems automatically records every time our Site is called up, such as: (1) information about the browser type and the version used; (2) operating system of the access device; (3) name of the accessing host; (4) IP address of the access device; (5) date and time of access; (6) Websites and resources (images, files, other site contents) accessed on our Site; (7) websites from which the user’s system accessed our Site (referrer tracking); (8) confirmation whether retrieval was successful; and (9) transferred data volume. access data: IP address, website from which the file was accessed, name of the file, date and time of access, amount of data transferred and report on the success of the access (so-called web log). We use this access data exclusively in non-personalized form for the continuous improvement of our Internet offering and for statistical purposes.
  • other information you choose to provide, such as when you visit the “Contact Us” page of our Site.

How We Use the Information We Obtain

We may use the information we obtain about you for various purposes, including to:

  • Provide goods or services;
  • Process business transactions and related activities;
  • Manage our relationships with our customers, suppliers and vendors;
  • Market our products and services;
  • Manage our career opportunities;
  • Respond to your inquiries;
  • Operate, evaluate and improve our business (including managing the Site; enhancing and improving our products and services; managing our communications; analyzing our products and services; performing data analytics; and performing auditing and other internal functions);
  • Customize your experience with our Site; and
  • Comply with and enforce applicable legal requirements, industry standards and Phoenix policies and terms.

We also may use the information in other ways for which we provide specific notice at the time of collection.

We use the information about you for the purposes described above because we have a legitimate interest in providing products and services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms in respect of your personal information.

We may use your information to fulfill a contract, or take steps linked to a contract, protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use information for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law.

We may also rely on consent through your consent, a free, unambiguous and clear confirming action or behaviour whereby you agree to the processing of your personal data for a given purpose (“consent”) as a legal basis for processing your personal information. For example, where required by applicable law, we will obtain your consent to send you marketing communications about our products and services and invite you to events. Where we rely on consent, we will inform you of the purposes for which we require your personal information at the point at which we obtain such personal information. Where you have provided your consent, you have the right to withdraw such consent at any time by contacting us as detailed in this Privacy Policy.

In addition to the uses described above, we may use information that you provide to us or that we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal information and our legal basis for doing so.

Your rights

  • Right to access

You are entitled to request a confirmation of whether we process your personal data. If this is the case, you have the right to access the information as long as the rights and freedoms of others are not adversely affected. We are glad to provide you a copy of this information.

  • Right to rectification

You are entitled to obtain the rectification of inaccurate personal data (such as address, name, etc.) any time. You may also request any time to have incomplete personal data completed. A corresponding adjustment is made immediately.

  • Right to erasure

You are entitled to request from us the erasure of your personal data if:

  • data are no longer required;
  • there is no longer any legal ground for processing because you withdraw your consent;
  • you object to the processing and there are not any legitimate grounds for the processing;
  • your data have been unlawfully processed;
  • this is required for compliance with a legal obligation.

However, you  cannot exercise this right if

  • processing is necessary for exercising the right of freedom of expression and information;
  • your data have been collected on the grounds of a legal duty;
  • processing is required for reasons in the public interest;
  • data are required for the enforcement, exercise or defence of legal claims.
  • Right to restriction of processing

You have the right to restrict the processing of your personal data in certain cases.

This applies if

  • the accuracy of the personal data is contested by you;
  • processing is unlawful and you oppose the erasure;
  • data are no longer required for the purpose of processing, but the collected data are used for enforcement, exercise or defence of legal claims;
  • an objection to processing has been made and the verification whether the legitimate grounds of whom override is still pending.
  • Right to withdraw your consent

If you have given us your explicit consent to the processing of your personal data, you may withdraw it any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of your consent until you withdraw your consent.

  • Right to object

You have the right to object at any time to processing of your personal data, which were collected based on the grounds of a legitimate interest. You only have this right if particular circumstances speak against storage and processing.

  • How do you exercise your rights?

You may exercise your rights any time by contacting us as follows:

Phoenix Services LLC

4 Radnor Corporate Center

100 Matsonford Rd.;

Suite 520

Radnor, PA 19087 USA

E-Mail: privacy@phoenix-services.com

Phone: +1.610.347.0444

Data safety and data protection, communication by e-mail

Your personal data will be protected by technical and organisational measures during collection, storage and processing so that third parties cannot access them. In case of unencrypted communication by e-mail, data security during transfer to our IT systems cannot be guaranteed in full by us so that we recommend to send information with a high need for confidentiality in encrypted form or by post.

Provision of our website and creation of log files

Every time our website is called up, our system automatically records data and information of the access device (e.g. computer, mobile phone, tablet, etc.) and other technical data as further described above.

Technical data is stored in our system’s log files. Technical data is not stored together with the personal data of a specific user so that it is not possible to identify individual users of the Site.

  • The legal basis for the processing of personal data contained in the technical data.

Legitimate interest to guarantee that the purpose described below is achieved.

  • Purpose of data processing

The temporary (automated) storage of technical data is only required during the Site visit so that the Site can be provided. Storage and processing of technical data is also required to maintain compatibility of our Site for all visitors, as far as possible, and to combat misuse and eliminate faults. It is necessary to log technical data of the accessing computer to be able to react promptly to incorrect visualisation, attacks to our IT systems and/or lack of functionality of our website. Furthermore, this data is used to optimise the website and to generally safeguard the security of our IT systems.

  • Length of time in storage

The above-mentioned technical data is erased as soon as they are no longer needed to guarantee compatibility of the website for all visitors but at the latest 3 months after you have visited our Site.

Special functions of the Site

Our Site offers you various functions, during the use of which personal data is collected, processed and stored by us. Below we explain what happens with this personal data:

Contact form(s)

  • What personal data is collected and to which extent will it be processed?

The personal data you entered in our contact forms, which you entered in the input mask of the contact form.

  • The legal basis for the processing of personal data

Your consent.

  • Purpose of data processing

We will use the personal data collected via our contact form or contact forms only for processing the specific contact request received through the contact form. Please note that in order to fulfil your contact request, we may also send you e-mails to the address provided. The purpose of this is so that you can receive confirmation from us that your request has been correctly forwarded. However, the sending of this confirmation e-mail is not obligatory for us and is only for your information.

  • Length of time in storage

After processing your request, the collected personal data will be deleted immediately, unless otherwise required by law.

  • The need to provide personal data

The use of the contact forms is on a voluntary basis and is neither contractually nor legally required. You are not obliged to contact us via the contact form, but can also use the other contact options provided on our Site. If you wish to use our contact form, you have to fill in the fields marked as mandatory. If you do not fill out the required information of the contact form, you can either not send the request or we can unfortunately not process your request.

Disclosure Of Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

  • By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

  • Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. See below additional details on third party service providers.

  • Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

  • Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Statistical analysis of visits to this Site – Web tracker

We collect, process and store the following access data when our Site or individual files on the Site are accessed: IP address, website from which the file was accessed, name of the file, date and time of access, amount of data transferred and report on the success of the access (so-called web log). We use this access data exclusively in non-personalized form for the continuous improvement of our Internet offering and for statistical purposes.

The legal basis for the transmission of personal data is your consent which you have provided on our Site.

We also use the following third party web trackers to evaluate visits to the Site:

  • Adobe Typekit

We use the Adobe Typekit service from Adobe Systems Software Ireland Limited, 4-6 Riverwalk Citywest Business Campus, 24 Dublin, Ireland, email: recepmun@adobe.com, website: http://www.adobe.com/. The processing also takes place in a third country for which there is no adequacy decision by the EU Commission. Therefore, the level of protection customary for the GDPR cannot be guaranteed during transmission, as it cannot be ruled out that in third countries, e.g. authorities, can gain access to the data collected.

Fonts are reloaded on our Site via the Adobe Typekit service in order to be able to show you a visually better version of the Site.

You can withdraw your consent at any time. You can find more information about withdrawing your consent either with the consent itself or at the end of this Privacy Policy.

Further information on the handling of the transmitted data can be found in the third party provider’s privacy policy at http://www.adobe.com/de/privacy.html.The third party provider also offers an opt-out option at https://www.adobe.com/de/privacy/opt-out.html.

  • Google Tag Manager

What personal data is collected and to which extent will it be processed?

On our Site, we use the service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Tag Manager). Google Tag Manager provides a technical platform for executing and bundling other web services and web tracking programs by means of so-called “tags”. In this context, Google Tag Manager stores cookies on your computer and analyses your surfing behaviour (so-called “tracking”), insofar as web tracking tools are executed by means of Google Tag Manager. This data sent by individual tags embedded in Google Tag Manager is aggregated, stored and processed by Google Tag Manager under a unified user interface. All integrated “tags” are listed separately again in this Privacy Policy. You can find more information on the data protection of the tools integrated in Google Tag Manager in the respective section of this Privacy Policy. When using our Site with activated integration of tags from Google Tag Manager, data, such as in particular your IP address and your user activities, are transmitted to servers of Google Ireland Limited. With regard to the web services integrated by means of Google Tag Manager, the regulations in the respective section of this privacy policy apply. The tracking tools used in Google Tag Manager ensure through IP anonymization of the source code that the IP address is anonymized by Google Tag Manager before transmission. In doing so, Google Tag Manager is only enabled to collect IP addresses anonymously (so-called IP masking).

Purpose of information processing

On our behalf, Google will use the information obtained by means of the Google Tag Manager to evaluate your visit to this Site, to compile reports on Site´s activity and to provide us with other services relating to website activity and internet usage.

  • Google-Analytics

Scope of the processing of personal data

On our Site, we use the web tracking service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Analytics). Within the scope of web tracking, Google Analytics uses cookies that are stored on your computer and enable an analysis of the use of our Site and your surfing behaviour (so-called tracking). We carry out this analysis based on the tracking service of Google Analytics in order to constantly optimize our Site and make it more accessible. When using our Site, data, such as in particular your IP address and your user activities, are transmitted to servers of the company Google Ireland Limited. We carry out this analysis on the basis of Google’s tracking service in order to constantly optimize our internet offer and make it better available. Likewise, we need the web tracking for security reasons. Web tracking allows us to track whether third parties are attacking our website. The information from the web tracker enables us to take effective countermeasures and protect the personal data processed by us from these cyber-attacks. By enabling IP anonymization within the Google Analytics tracking code of this website, your IP address will be anonymized by Google Analytics before transmission. This website uses a Google Analytics tracking code that has been extended by the operator gat._anonymizeIp(); to enable only anonymized collection of IP addresses (so-called IP masking).

Purpose of information processing

On our behalf, Google will use this information for the purpose of evaluating your visit to this Site, compiling reports on the Site activity and providing us with other services relating to website activity and internet usage. Likewise, we need the web tracking for security reasons. Web tracking allows us to track whether third parties are attacking our Site. The information from the web tracker allows us to take effective measures to counteract and protect the personal data we process from these cyberattacks.

  • For Google Tag Manager and Google-Analytics the following also applies

Length of time in storage

Google will store the data relevant for the provision of Google Tag Manager and Google-Analytics for as long as it is necessary to fulfil the booked / contracted web service. The personal data collection and storage are anonymized. If there is a reference to a person, the personal data will be deleted immediately, insofar as this is not subject to any legal retention obligations. In any case, the deletion takes place after the expiration of the retention obligation.

Right to object and to erasure

You can prevent the collection and forwarding of personal data to Google (in particular your IP address) as well as the processing of this data by Google by deactivating the execution of script code in your browser, by installing a script blocker in your browser or by activating the “Do Not Track” setting of your browser. You can also prevent the collection of data generated by the Google cookie and related to your use of the website (including your IP address) to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link http://tools.google.com/dlpage/gaoptout?hl=de. Google’s security and privacy policy can be found at https://policies.google.com/privacy.

 

Integration of external web services and processing of personal data outside the EU

On our Site, we use active content from external third party providers, so-called web services. When you visit our Site, these external third party providers may receive personal information about your visit to our Site. This may involve the processing of data outside the EU. You can prevent this by installing an appropriate browser plug-in or disabling the execution of scripts in your browser. This may result in some functional restrictions on the websites that you visit.

The legal basis for the transmission of personal data is your consent which you have provided on our Site.

We use the following external web services:

  • Google

We use on our site the service Google of the company Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States, e-mail: support-de@google.com, website: http://www.google.com/. The processing also takes place in a third country for which there is no Commission adequacy decision. Therefore, the usual level of protection for the GDPR cannot be guaranteed for the transfer, as it cannot be ruled out that in the third country, e.g. authorities can access the collected data.

The legal basis for the transmission of personal data is your consent which you have provided on our Site. We use Google in order to be able to reload further services from Google on the website.

You can withdraw your consent at any time. You can find more information about withdrawing your consent either with the consent itself or at the end of this privacy policy.

For more information on the handling of transmitted data, please refer to the provider’s privacy policy at https://policies.google.com/privacy.

  • Google Maps

What personal data is collected and to which extent will it be processed?

On our website, we use the map service of the company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Maps). Google Maps is integrated on the website via the Google API to visualize location information and display it in the form of a map. To display the map, the processing of the IP address by Google Maps is technically necessary. With regard to the other web services integrated via Google Apis, the regulations in the respective section of this privacy policy for Google Apis apply.

The legal basis for the processing of personal data

Legitimate interest is to be able to present you with the usual presentation of location information on the Internet in a visualized form.

Purpose of data processing

On our behalf, Google will use the information obtained by means of Google Maps to show you the map. By means of Google Maps you will find us faster and more accurately than with a mere non-interactive map.

Length of time in storage

Google will store the personal data relevant for the function of Google Maps as long as it is necessary to fulfil the booked web service. The personal data collection and storage are anonymized. If there is a reference to a person, the data will be deleted immediately, insofar as this is not subject to any statutory retention obligations. In any case, the deletion takes place after the expiration of the retention obligation.

Right to object and to erasure

You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the “Do Not Track” setting of your browser. Google’s security and privacy policies can be found at https://policies.google.com/privacy.

Joint processing

We have concluded a joint processing agreement with Google with regard to Google Maps.

You can find the content at https://privacy.google.com/intl/de/businesses/mapscontrollerterms/.

  • Google APIS and Gstatic

We use on our site the service Google APIS and Gstatic of the company Google LLC, 1600 Amphitheatre Parkway, 94043 Mountain View, United States of America, e-mail: support-de@google.com, website: http://www.google.com/. The processing also takes place in a third country for which there is no Commission adequacy decision. Therefore, the usual level of protection for the GDPR cannot be guaranteed for the transfer, as it cannot be ruled out that in the third country, authorities can access the collected data.

The legal basis for the transmission of personal data is your consent which you have provided on our Site. We use Google APIS to be able to reload additional services from Google on the website. Google Apis is a collection of interfaces for communication between the various Google services that are used on your website. The service or we collect the following data for processing: IP address.

Gstatic is a service used by Google to retrieve static content in order to reduce bandwidth usage and to preload required catalogue files.

You can withdraw your consent at any time. You can find more information about withdrawing your consent either with the consent itself or at the end of this privacy policy.

For more information on the handling of transmitted data, please refer to the provider’s privacy policy at https://policies.google.com/privacy.

  • JQuery

We use on our site the service JQuery of the company The Linux Foundation, 1 Letterman Drive, Building D, Suite D4700, CA 94129 San Francisco, United States, email: legal@js.foundation, website: https://js.foundation/. The processing also takes place in a third country for which there is no Commission adequacy decision. Therefore, the usual level of protection for the GDPR cannot be guaranteed for the transfer, as it cannot be ruled out that in the third country, e.g. authorities can access the collected data.

The legal basis for the transmission of personal data is your consent which you have provided on our Site. jQuery is a free JavaScript library that is required for the proper operation of our website. It contains a code database that is a basic requirement for many features of our website.

You can withdraw your consent at any time. You can find more information about withdrawing your consent either with the consent itself or at the end of this privacy policy.

For more information on the handling of transmitted data, please refer to the provider’s privacy policy at https://js.foundation/wp-content/uploads/sites/33/2017/03/JS-Foundation-IP-Policy.pdf.

Information about the use of cookies

Scope for processing personal data

We embed and use cookies at different pages to enable certain functions of our website and to embed external web services. So-called “cookies” are small text files your browser can store on your access device. These text files contain a characteristic string chain, which uniquely identifies your browser when you come back to our website. Storage of a cookie file is also called “setting a cookie”. Cookies can be set both by our website and by external web services.

The legal basis for the processing of personal data

Legitimate interest and/or your consent.

The relevant legal basis can be seen in the cookie table further below.

In general, the legitimate interest for cookies set based on a legitimate interest is to guarantee functionality of our website and the embedded services (technically required cookies). It may also be possible that cookies increase user-friendliness and allow for a more individual addressing. We have weighed up your interests against our interests.

By using cookie technology, we can identify, analyse and track individual website users if the visitor has consented to the use of cookies.

Purpose of data processing

The cookies are set by our Siteand/or external web services to achieve full functionality of our website, to improve user-friendliness and to pursue the purpose stated with your consent. Cookie technology allows us to recognise individual visitors based on pseudonyms, such as an individual or random ID, so that we can offer more individualised services. Details are listed in the following table.

Length of time in storage

The cookies listed in the following are stored in your browser until they are deleted or, in case of a session cookie, until the session has expired. Details are listed in the following table:

Cookie Name Server Provider Purpose Legal basis Duration of storage Type
_gid phoenix-services.com Google-Analytics This cookie assigns an ID to a user so that the web tracker can summarize the user’s actions under this ID. Consent approx. 24 hours         Analytics
_ga phoenix-services.com Google-Analytics This cookie assigns an ID to a user so that the web tracker can summarize the user’s actions under this ID. Consent approx. 24 months        Analytics
gat_gtag_UA* phoenix-services.com Google-Analytics This cookie assigns an ID to a user and associates the user’s actions under this ID in connection with Google Tag Manager. Consent approx. 70 seconds         Analytics
CONSENT .google.com Google The cookie used assigns an ID to the site visitor and collects statistical data on the site visits of the site visitor. This serves to individualize the advertising displayed to the visitor. Consent approx. 16 years         Marketing
phxservcookie www.phoenix-services.com Phoenix This cookie allows us to store individual comfort settings you have chosen and keep them for your current and future visits to our site. Consent approx. 12 months   Configuration

 

Right to object, withdrawal of consent and erasure

You can set your browser as you wish so that the setting of cookies is generally prevented. You may then decide on a case-by-case basis whether you accept a cookie or generally accept cookies. Cookies can be used for different purposes, e.g. to recognise whether your access device is already connected to our website (permanent cookies) or to save last viewed offers (session cookies). If you have given us your explicit consent to the processing of your personal data, you may withdraw this consent any time. Please note that this does not affect the lawfulness of the processing carried out on the basis of your consent until you withdraw your consent.

Additional Information for EU visitors

Right to data portability

Under Art. 20 of the GDPR, you have the right to have your personal data transferred to you. We provide your personal data in a structured, commonly used and machine-readable format. The data can either be transferred to you or a controller you specify.

On request, we provide you the following data acc. to Art. 20 para. 1 of the GDPR:

  • data collected based on an explicit consent pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR;
  • data we have received from you for the performance of a contract acc. to Art. 6 para. 1 lit. b GDPR;
  • data having been processed in automated procedures.

We will transfer the personal data directly to a controller specified by you insofar as this is technically feasible. Please note that according to Art. 20 para. 4 GDPR we may not transfer data which adversely affect the rights and freedoms of others.

Right to complain to supervisory authority pursuant to Art. 77 para. 1 of the GDPR

Insofar as you suspect that your data are being processed unlawfully on our Site, you may, of course, bring about a judicial clarification of the issue at any time. In addition, any other legal option is open to you. Irrespective of that, you may contact a supervisory authority based on Art. 77 para. 1 of the GDPR. You have a right to lodge a complaint pursuant to Art. 77 of the GDPR in the Member State of your habitual residence, place of work or place of the alleged infringement, i.e. you can choose the supervisory authority of one of the above-mentioned places. The supervisory authority with whom the complaint is lodged shall notify you of the status and outcomes of your complaint, including your right to an effective judicial remedy based on Art. 78 of the GDPR.

Additional Information for Brazilian visitors

Additional Exceptions to the Right to Erasure

In addition to the exceptions outlined above, according to Art. 16 of the LGPD, you also do not have this right if:

  • processing is necessary due to controller need to comply with a legal or regulatory obligation;
  • there is in place a study by a research entity, ensuring, whenever possible, the anonymization of the personal data;
  • data was transferred by controller to third parties, provided that the requirements for data processing as provided in the LGPD are obeyed; and
  • data is used exclusively by the controller, with access by third parties being prohibited, and provided the data has been anonymized.

Right to restriction of processing

Refer to the circumstances provided in Art. 15 of the LGPD.

Right to data portability

Under Art. 11, para 4, I; Art. 18, V; and Art. 18, para 7 of the LGPD, you have the right to have your personal data transferred to you. We provide your personal data in a structured, commonly used and machine-readable format. The data can either be transferred to you or a controller you specify.

On request, we provide you the following data:

  • data collected based on an explicit consent;
  • data we have received from you for the performance of a contract;
  • data having been processed in automated procedures.

We will transfer the personal data directly to a controller specified by you insofar as this is technically feasible. Please note that we may not transfer data which adversely affect the rights and freedoms of others.

Under Art. 18, V of the LGPD, you may at any time and by means of request, has the right to obtain portability of your data to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets. If it is impossible to immediately adopt the request mentioned above, we will send you a reply communicating we are not the data processing agent and indicate, whenever possible, who the agent is; or we will indicate the reasons of fact or of law that prevent the immediate adoption of such request.

The right of portability referred to above does not include your data that have already been anonymized by us.

Right to complain to supervisory authority pursuant to Art. 18, I of the LGPD.

Insofar as you suspect that your data are being processed unlawfully on our Site, you may, of course, bring about a judicial clarification of the issue at any time. In addition, any other legal option is open to you. Irrespective of that, you may contact a supervisory authority based on Art. 18, I of the LGPD.

You have a right to lodge a complaint. The supervisory authority with whom the complaint is lodged shall notify you of the status and outcomes of your complaint, including your right to an effective judicial remedy.

Data subjects may exercise their rights regarding their personal data through the (legal) person accountable for the processing of personal data, the Data Protection Officer (the DPO). The DPO is appointed by the controller to act as a communication channel between the controller, the data subjects, and the local Data Protection Authority.

The DPO is responsible (among other tasks) for accepting complaints and communications from the data subjects, providing clarifications, and taking necessary actions.

You may exercise your rights any time by contacting our nominated Brazil DPO as follows:

InterExpand SAS

World Trade Center 10/12 Bd Vivier Merle

69393 Lyon

Cedex 03 FRANCE

Email: dpo.phoenixbr@interexpand.com

Phone: 33 613234029

Additional Information for California visitors

Sources of Personal Information

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

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our Site. For example, from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any personal information. We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any third party, we will provide you with the opt-out rights required under CCPA.

Your Rights and Choices

  • Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request, 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.

– The specific pieces of personal information we collected about you (also called a data portability request).

– Sales (if any), 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.

To exercise these rights, please contact us. Please refer to the contact details at the bottom of this Privacy Policy.

  • 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 level or quality of goods or services.

Our contact details

Phoenix Services LLC

4 Radnor Corporate Center

100 Matsonford Rd.; Suite 520

Radnor, PA 19087 USA

E-mail: info@phoenix-services.com

Phone: +1.610.347.0444