Privacy Policy
Last Updated: December 5, 2022
This Privacy Policy (hereinafter referred to as “Policy”) is aimed at assisting you to understand the privacy details about how PHOENIX (hereinafter referred to “PHOENIX” and “We”) manages the Personal Data you provide to PHOENIX while using our products or services, including how PHOENIX collects, processes and transmits your Personal Data, etc.
Once you use our products or services, you shall be deemed to have read, agreed and accepted all terms and conditions stated in this Policy as well as all the changes we have made at any time. PHOENIX respects and protects your personal privacy. Please read carefully and understand this Policy before providing or allowing your personal data be collected by PHOENIX.
1. How PHOENIX collects and uses your Personal Data
Personal Data PHOENIX may collect and use through the Service or otherwise includes:
Device data. We collect data from or about your devices where you install or access our Service, which helps us provide consistent Services across your devices. Device data may include: IDFA, IDFV, device model and screen resolution. Please understand that this data is essential for us to provide our services and to ensure the proper functioning of our products.
Country and Language. We collect general information such as country and language of the users directly from the iOS API in order to provide more consistent Services.
Feedback data. You can give us feedback on problems you are experiencing with the product in the feedback interface of PHOENIX. During this process, we collect data about your most recent actions and the content of the messages you send us, such as feedback, survey data and product reviews that you write.
Crash Report. By default, When PHOENIX crashes, crash reports are sent to PHOENIX to help us fix crashes and improve our products. Crash reports contain system information at the time of the crash, and may contain web page URLs or personal data, depending on what was happening at the time the crash report was triggered.
2. How we store your Personal Data
The data collected by PHOENIX will be stored in a secure database. We will ensure that your Personal Data is adequately protected through technical measures. Currently, we don't process your Personal Data across borders. However, if we need to transfer your Personal Data across borders in the future due to business development, we will do so in accordance with applicable laws and regulations.
With respect to retention period, we will only retain your Personal Data for as long as necessary to achieve the purposes described in this policy, unless there is a mandatory retention requirement by law. Specifically, we determine the retention period by reference to the following criteria:
a) to fulfil the business and service purposes relating to you in response to any inquiries or complaints you may have.
b) to ensure the security and quality of services we provide to you.
c) the existence of other special agreements or legal and regulatory requirements regarding the retention period.
After the retention period has expired, we will delete or anonymize your Personal Data as required by applicable law.
3. How PHOENIX disclose your Personal Data
Under the relevant applicable laws, PHOENIX may disclose your Personal Data under the following situations:
a) PHOENIX has obtained your express consent for the disclosure of data and will only disclose it to the extent that you have consented.
b) For the purposes stated in this Privacy Policy only, we may share your Personal Data with our suppliers, service providers, consultants or agents for the purpose of providing basic customer service. These suppliers, service providers, consultants or agents provide us with technical infrastructure services, analyze how our services are used, measure the effectiveness of advertising and services, provide customer service and payment services, conduct academic research and surveys, or provide legal, financial and technical advisory services. PHOENIX will conduct a prior review of the data security capabilities of vendors, service providers, consultants or agents before data is disclosed.
c) To the extent permitted by law or regulation, PHOENIX may disclose your Personal Data under other circumstances where such disclosure is required for universal justice as deemed by PHOENIX. Such circumstances include the disclosure to prevent personal injury or death, to avoid significant property loss or to protect the social public interest.
d) In order to execute or to assist in executing some legal or administrative procedures, PHOENIX may provide your Personal Data to the relevant law enforcement agencies or government sectors.
4. Cookies
A cookie is a neutral technology that allows a web server to store data on or read from a client. Cookie files are files that store some information about a user's visit to a website in .text format and the cookie content is usually encrypted.
PHOENIX uses secure cookie technology to provide you with a more convenient service. We use cookies for the following purposes in general.
a) Preferences: Cookies can help us provide services to you in accordance with the personalized settings of the service style and appearance you want. The cookie records the font size, resolution and other factors you set before, so that it can be automatically adjusted to the previous settings for you when you visit again.
b) Security: Cookies help us to keep our data and services secure and to detect hacking, fraud and other activity against our products and services.
c) Efficiency: Cookies help to avoid unnecessary server load and improve service efficiency.
d) Analysis and research: Cookies can help us understand and improve our products and services and provide reference data for the development of new functions or new products.
5. Security measures PHOENIX take to protect your Personal Data
We will provide security measures to PHOENIX users. We will take reasonable and practicable measures to protect your Personal Data that we collect and prevent your Personal Data from being accessed, tampered with, disclosed or destroyed by unauthorized third parties. For example, there are duties of confidentiality in the contract signed between PHOENIX and its partners. If a partner breaches the confidentiality obligation in the contract and brings about losses to the obligee, PHOENIX will impose legal liabilities on the partner and terminate the business relationship with the partner.
There is no absolutely safe website, internet transmission, computer system and wireless connections. Except the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when skipping to third party websites, links, products or services through our services, please carefully read through the terms and conditions or privacy policies of such websites, links, products or services regarding the security of the data and information collected by them. PHOENIX shall not be liable for any actions you make thereof. If you find certain contents, advertisements, or functions in our products or services that may be possibly provided by third parties, and may possibly endanger your privacy and security, please contact PHOENIX at verizontal.phx@gmail.com and we will handle that priority.
6. Your Rights
You have the right to make a request to access or delete any of your Personal Data that we might possess. To request exercising your rights under the applicable law, please fill out the form attached to this Policy and send to us via email at verizontal.phx@gmail.com. After receiving your request, we will process within the period of time as prescribed by applicable law. You may be required to provide additional information to authenticate your request.
7. How PHOENIX process Personal Data of Children
PHOENIX understands the importance of safeguarding the Personal Data of children. Our products, websites and Services are not intended for use by any children. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
8. Update of this Policy
PHOENIX reserves the right to modify this Privacy Policy. When we post changes to this Privacy Policy, we will include the date when the statement was last updated. If we significantly change this statement, we will notify you about the upcoming change via our website or using in-app notifications.
We encourage you to review this statement periodically. By continuing to use PHOENIX products and services, you are agreeing to be bound by the revised Privacy Policy.
9. How to contact PHOENIX
PHOENIX has appointed a Data Protection Officer. For any questions in relation to the protection of personal privacy, please contact our Data Protection Officer by filling out the form attached to this Policy. Send the completed form to our email address, verizontal.phx@gmail.com.
Feedback Form for Personal Information and Privacy Questions.docx