Protecting the individual’s privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual`s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual (“Personal Data”).

Who is the Data Controller?

WEBSITES

The responsible data controller for Phoenix Business, Inc. and associated websites (phoenixteam.com) is Phoenix Business, Inc. 5021 Midnight Pass Rd. Sarasota, FL 34242 (Phoenix) and its data protection officer can be reached at privacy@phoenixteam.com

REGISTRATIONS

Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form’s privacy statement.

PHOENIX GOODS AND SERVICES

Upon entering into a contract with Phoenix for a good or service provided by Phoenix, Phoenix may use your personal data, such as your name, email address and postal address, telephone number, financial information (such as credit card information, bank details, and invoice information), to complete transactions. The respective Data Controller then is identified as the country where the transaction is completed and the list of individual country data controllers can be found below.

United States and all other Countries not otherwise listed:

Phoenix Business Inc.

5021 Midnight Pass Rd.

Sarasota, FL 34242

USA

What Personal Data does Phoenix collect?

Phoenix collects some information about you in the context of your professional activities, consisting of your name, your (professional) email addresses, and (professional) telephone numbers, your company name and your company address. When you visit this Phoenix website, Phoenix stores certain information about your browser, the operating system, and your IP address.

Why does Phoenix need your Personal Data?

Phoenix requires your Personal Data to:

  • provide you with access to this website;
  • to deliver the ordered goods or services;
  • comply with statutory obligations, including checks required by applicable export laws.

Although providing Personal Data is voluntary, without your Personal Data, Phoenix cannot deliver the ordered goods or services.

Kindly note that you can use this website, purchase solutions, and contact Phoenix Partners even without providing a consent into Phoenix’s marketing operations.

How long will Phoenix store my Personal Data?

Phoenix will only store your Personal Data for as long as it is required:

  • to make purchased solutions available to you;
  • for Phoenix to comply with its statutory obligations resulting from applicable export laws:
  • to provide you with solutions, services, or support until you object against such use by Phoenix if Phoenix’s use of your Personal Data is based on Phoenix’s legitimate business interest as further stated in this Privacy Statement;
  • to enable Phoenix Partners to contact you in response to your requests or until you revoke your consent granted in this Privacy Statement if Phoenix is processing your Personal Data based on your consent;
  • by applicable mandatory law to retain your Personal Data longer or where your Personal Data is required for Phoenix to assert or defend against legal claims, Phoenix will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

Who are the recipients of your Personal Data and where will it be processed?

Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:

  • companies within the Phoenix Business, Inc. group of Companies
  • vicarious agents, e.g. third-party servicers for consulting services and other additional related services
  • other service providers, e.g. for the provision of the website or newsletter dispatch As part of a global group of companies operating internationally, Phoenix has affiliates (the “Phoenix Group”) and third-party service providers outside of the European Economic Area (the “EEA”) and will transfer your Personal Data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, Phoenix uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant) of such standard contractual clauses by sending a request to privacy@phoenixteam.com. You can also obtain more information from the European Commission on the international dimension of data protection here: European Commission

What are your data protection rights?

YOU CAN REQUEST FROM PHOENIX:

Access at any time to information about which Personal Data Phoenix processes about you and the correction or deletion of such Personal Data. Please note, however, that Phoenix can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Phoenix to retain it. Kindly note further that if you request that Phoenix deletes your Personal Data, you will not be able to continue to use any Phoenix service that requires Phoenix’s use of your Personal Data.

If Phoenix uses your Personal Data based on your consent or to perform a contract with you, you can further request from Phoenix a copy of the Personal Data that you have provided to Phoenix. In this case, please contact privacy@phoenixteam.com and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. Phoenix will carefully consider your request and discuss with you how it can best fulfill it.

Furthermore, you can request from Phoenix that Phoenix restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Phoenix has about you is incorrect, subject to the time Phoenix requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for Phoenix processing your Personal Data and you demand that Phoenix restricts your Personal Data from further processing, (iii) Phoenix no longer requires your Personal Data but you state that you require Phoenix to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Phoenix based on Phoenix’s legitimate interest (as further set out below), subject to the time required for Phoenix to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

FOR INDIVIDUALS WITHIN THE STATE OF CALIFORNIA, YOU INSTEAD HAVE THE RIGHT:

  • To request from Phoenix access to your Personal Data that Phoenix collects, uses, discloses, or sells (if applicable) about you;
  • To request that Phoenix delete Personal Data about you;
  • To non-discriminatory treatment for exercise of any of your data protection rights to non-discriminatory treatment for exercise of any of your data protection rights
  • In case of request from Phoenix for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance; and
  • To opt-out of the sale of Personal Data. In accordance with the disclosure requirements under the California Consumer Privacy Act (“CCPA”), Phoenix is exempt from providing a notice to opt-out because it does not and will not sell your Personal Data.

Please note, however, that Phoenix can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Phoenix to retain it. Kindly note further that if you request that Phoenix deletes your Personal Data, you will not be able to continue to use any Phoenix service that requires Phoenix’s use of your Personal Data.

How can you exercise your data protection rights?

Please direct any requests to exercise your rights to security@phoenixteam.com. You can also designate another person to submit requests to exercise your data protection rights to Phoenix. You can give authorization to such person by granting them a limited power of attorney to exercise your data protection rights on your behalf.

How will Phoenix verify requests to exercise data protection rights?

Phoenix will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Phoenix will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by Phoenix. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by us.

In accordance with the verification process set forth in the CCPA, Phoenix will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data. If Phoenix must request additional information from you outside of information that is already maintained by Phoenix, Phoenix will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

Phoenix will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law. If you take the view that Phoenix is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where Phoenix has its registered seat.

Can I use Phoenix’s goods and services if I am a minor or child?

CHILDREN.

Phoenix websites and online services are not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with and use this websites or online services.

U.S. CHILDREN’S PRIVACY.

Phoenix does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe Phoenix collected information about a child, please contact Phoenix as described in this Privacy Statement. Phoenix will take steps to delete the information as soon as possible. Given that Phoenix websites and online services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, Phoenix does not sell the Personal Data of any minors under 16 years of age.

Processing Based on a Statutory Permission

Why does Phoenix need to use my Personal Data and on what legal basis is Phoenix using it?

PROCESSING TO FULFILL CONTRACTUAL OBLIGATION.

Phoenix requires your Personal Data to deliver goods or services you order under a contract Phoenix has with you, to establish a contract for goods or services between you and Phoenix, and to send you invoices for ordered goods or services. Phoenix processes Personal Data to fulfill contractual obligations pursuant to Article 6(1), Subparagraph 1(b) GDPR. If you order goods or services from Phoenix, Phoenix will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, if payment is to be made to Phoenix, credit card number or bank details) only to process your order or to provide the requested goods or service. This may include taking the necessary steps prior to entering into the contract, responding to your related inquiries, and providing you with shipping and billing information and to process or provide customer feedback and support. This may also include conversation data that you may trigger via the chat functionalities on Phoenix Digital Commerce (store.sap.com, partner.store.sap.com, www.sapstore.com) or other local Phoenix web presences, contact forms, emails, or telephone. In this Privacy Statement, “goods and services” includes (access to) Phoenix’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events. If you participate in tutorials or trainings provided by Phoenix, Phoenix may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), Phoenix will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time at https://www.phoenixteam.com/unsubscribe

PROCESSING TO ENSURE COMPLIANCE.

Phoenix and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Phoenix is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Phoenix’s websites or other delivery channels controlled by Phoenix. This could include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Phoenix’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match. Any such use of your Personal Data is based on the permission to process Personal Data in order to comply with statutory obligations (Article 6 para. 1 lit. c GDPR) and Phoenix‘s legitimate interest (Article 6 para. 1 lit. f GDPR).

PROCESSING BASED ON PHOENIX’S LEGITIMATE INTEREST.

  • Fraud and Legal Claims. If required, Phoenix will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
  • Questionnaires and survey. Phoenix could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, Phoenix will use this personal data to improve its products and services.
  • Contract Performance. If you purchase or intend to purchase goods or services from Phoenix on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a “Customer Contact”) and Phoenix, Phoenix will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs Phoenix that you are his replacement, Phoenix will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
  • Creation of anonymized data sets. Phoenix will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
  • Personalized Newsletter. If you opt-in to receive marketing communications such as newsletters from Phoenix, Phoenix will collect and store details of how you interact with the newsletters to help create, develop, operate, deliver and improve our newsletter communications with you. This information is aggregated and used to help Phoenix provide more useful information and to understand what is of most interest.
  • Recordings for quality improvement purposes. In case of telephone calls or chat sessions, Phoenix will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of Phoenix’s services.
  • To keep you up-to-date or request feedback. Within an existing business relationship between you and Phoenix, Phoenix might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from Phoenix. Furthermore, where you have attended a webinar, seminar or event of Phoenix or purchased products or services from Phoenix, Phoenix might contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

RIGHT TO OBJECT.

You can at any time object to Phoenix’s use of your Personal Data as set forth in this section by sending an email to privacy@phoenixteam.com – In this case, Phoenix will carefully review your objection and cease further use of the relevant information, subject to Phoenix’s compelling legitimate grounds for continued use of the information, which override your interest in objecting, or if Phoenix requires the information for the establishment, exercise or defense of legal claims.

Processing based on consent

In the following cases, Phoenix will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6(1) lit. a GDPR). If you re-open this Privacy Statement after you initially grant one or more consents, you will see the full Privacy Statement and not just information on the consents you granted.

News about Phoenix’s Products and Services. Subject to a respective provision and your consent, Phoenix may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Phoenix (prior purchases, participation in webinars, seminars, or events or the use of (web) services in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Phoenix’s software and services (including marketing-related newsletters) as well as events of Phoenix and in order to display relevant content on Phoenix’s websites. In connection with these marketing-related activities, Phoenix may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.

Creating user profiles. Phoenix offers you the option to use its web offerings including forums, blogs, and networks (such as the Phoenix Community) linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of Phoenix or, if created in the Phoenix Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of Phoenix or of other entities of the Phoenix Group, or both (irrespective of any consent granted under the section “Forwarding your Personal Data to other Phoenix companies.” below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for Phoenix to create such user profiles Phoenix will not be in a position to offer such services to you where your consent is a statutory requirement that Phoenix can provide these services to you.

Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by Phoenix to foster the quality of communication and collaboration through such offerings and for Phoenix to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share. Special categories of Personal Data. In connection with the registration for and provision of access to an event or seminar, Phoenix may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder.

Kindly note that if you do not provide any such information about disabilities or special dietary requirements, Phoenix will not be able to take any respective precautions. Event profiling. If you register for an event, seminar, or webinar of Phoenix, Phoenix may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.

Forwarding your Personal Data to other Phoenix companies. Phoenix may transfer your Personal Data to other entities in the Phoenix Group. The current list of Phoenix Group entities can be found here. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above. Forwarding your Personal Data to other third Parties. At your request, as indicated by your consent, Phoenix will transfer your registration data to the companies listed on the registration page. The companies will use your registration data for the purposes of their participation in the event and are obliged to delete the data thereafter. If a company intends to use your data for any other purposes, they will contact you to explain how and for which other purposes they will use your registration data.

Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://www.phoenixteam.com/unsubscribe In case of withdrawal, Phoenix will not process Personal Data subject to this consent any longer unless legally required to do so. In case Phoenix is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Phoenix up to the point in time of your withdrawal. Furthermore, if your use of a Phoenix offering requires your prior consent, Phoenix will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for Phoenix to use your profile under the Phoenix Cloud Platform Identity Authentication Service for multiple Phoenix offerings), offer or event to you after your revocation.

Additional Country-Specific Provisions

Where Phoenix is subject to U.S. privacy requirements, the following also applies:

Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honor “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.