(Effective Date: July 19, 2023)
This PHRUTOS Privacy & Cookies Policy (this “Privacy Policy”) explains how your personal information is collected, used and disclosed by PHRUTOS, LLC. and the PHRUTOS affiliates listed in the “Data Controllers and Contacting Us” section below (“PHRUTOS”, “us”, or “we”) and how we collect information through the use of cookies and related technologies. It also tells you how you can access and update your personal information and describes the data protection rights that may be available under your country’s or state’s laws, including (in the European Economic Area (“EEA”)) a right to object to some processing that we carry out or, where we rely on consent, how to withdraw that consent.
This Privacy Policy applies to the personal information we obtain from or about you when you (i) visit all internet sites operated by PHRUTOS that link to this Privacy Policy (collectively, the “Sites“); (ii) interact with our social media pages and advertisements, customer services, webinars or blogs; or (iii) participate in our events and demonstrations. PHRUTOS acts as the data controller for the data processing operations described in this Privacy Policy.
We may provide additional information about our privacy practices at other points, for example, when we ask you to provide personal information in connection with a particular service, and where this will help us provide more relevant and timely information.
We reserve the right to make changes to our practices and this Privacy Policy at any time. If we change the way we handle your personal information, we will update this Privacy Policy and notify you as appropriate.
This Privacy Policy addresses the following:
Information that we collect about you
Cookies and other tracking technology that we use
Uses made of your personal information and our legal basis for processing
Disclosures of your personal information
Withdrawing consent or otherwise objecting to PHRUTOS’s direct marketing
EEA data protection rights
California privacy notice
Miscellaneous
1. INFORMATION THAT WE COLLECT ABOUT YOU
Customers and Website Users
Information Provided by You Upon Registration and/or Making a Purchase. When you register for an account on a Site and/or purchase a product or service from us, we collect information that allows us to identify you, such as:
Name
E-mail address
Address (where entered as part of a “business/location scan”)
ZIP/Postal Code
Home Phone
Mobile Phone
Credit Card Number
Billing Address
PHRUTOS login details (username and password)
Information Provided When You Contact Us. We also collect personal information that you voluntarily provide to us when you contact us with a question or comment about our products and services, download our whitepapers or sign up for product demonstrations or events. Typically, this includes:
Name
E-mail address
Organization Name
Phone Number
Information about your position
Information about your interests and preferences
Content of the communication
Passively Collected Information. When you access our Sites, we automatically collect (i) technical information about your device including your device’s internet protocol (IP) address, your browser type and version, time zone setting, and operating system and platform; and (ii) information about your visit, including the URL clickstream to, through and from our Sites (including date and time), products you viewed or searched for, your account activity (when logged in), the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies. See Section 2 for more detail.
Information Collected From Our Partners. We may partner with our third party resellers to receive information about you, such as name and contact information. This helps us to fulfill your service requests and/or to provide you with services that may be of interest to you.
Information Collected in Connection with our Review Services or other Services. Where our customers use our review service or other services, we compile statistical and other information related to the performance and operation of the relevant service and will use or share with our customers and prospective customers, aggregated information collected from reviewers or other users of our services for research and development purposes or to provide analytics, reports and benchmarking about our services (e.g. average location ratings or frequently used terms within the reviews). We also use such aggregated information for our own advertising and promotional purposes.
If you use our services to solicit reviews or otherwise process information about your customers, we will collect, on your behalf, the personal information and any other information provided about your customers (“End Users”). We will use the information provided by End Users to provide services to you. We have no direct relationship with End Users. You are responsible for ensuring that you have the appropriate consent for us to collect and process End Users’ information to provide our services. If you are an End User and believe you have received an email from us on behalf of one of our customers, please contact that company directly with any questions.
Partners, Publishers and other Service Providers.
We will process certain contact information about individuals within organizations that we work with such as publishers, mailing houses, payment providers, IT hosting and maintenance providers, events companies and other service providers.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE
We and our service providers use cookies, beacons, embedded scripts and local shared objects in connection with the Sites.
Cookies are small text files that are stored on your computer when you visit our websites. Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website.
Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Sites and in email communications and typically work in conjunction with cookies to identify our users, their devices and behaviour, type of email applications used, screen resolution in order to check if our communications have been opened and acted upon, and to provide content and ads that are more relevant to you.
An embedded script is a 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.
Local Shared Objects. Local shared objects (or Flash cookies) are pieces of data that websites which use Adobe Flash may store on a user’s computer or device. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity use local shared objects. Various browsers may offer their own management tools for removing local shared objects. In addition, you may manage Flash cookies by clicking here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
The above technologies are used in analyzing trends, administering the Sites, services and products, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Categories of Sources. We collect this personal information from the following categories of sources:
Individuals, when you provide it to us directly or by using our Sites;
Service providers;
Partners that are authorized to resell PHRUTOS services;
Event organizers of events you register to attend; and
Commercial data resellers.
Why We Collect, Use, and Share California Information. We use and disclose this personal information for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes including, without limitation:
Our commercial purposes, including advertising and marketing to you, and enabling commercial transactions with you.
Our business purposes as identified in the CCPA, which include:
Auditing related to our interactions with you;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Internal operations;
Activities to maintain and improve our services; and
Other one-time uses.
Recipients of California Personal Information. We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:
Service providers, including internet service providers, data analytics providers, and operating systems and platform providers; and
Partners that are authorized to resell PHRUTOS services;
Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
The right to request that we delete the personal information we have collected from you or maintain about you.
The right to opt out of our sale(s) of your personal information. We do not and will not sell your personal information in any manner that requires an opt-out opportunity under the CCPA.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
Online at this link
Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your name, business email address, and business phone number. Please see the online form for details.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by submitting a written, signed permission here. Please see the online form for details.
Minors. We do not sell the personal information of minors under 16 years of age.
8. MISCELLANEOUS
Third-Party Websites. The Sites may contain links to third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such websites. Please contact these third-parties directly for information regarding their privacy practices prior to providing them with any information. Some of our solutions are integrated into our customers’ own websites, applications and communications (“Customer Solutions“). Where this is the case, we do not interact directly with the ultimate end user of these Customer Solutions and the customer will be responsible for the operation of these Customer Solutions and any personal information collected in connection therewith. We are not responsible for the processing of personal information by these Customer Solutions save to the extent that we receive any personal information via these Customer Solutions on behalf of the customer in order to fulfill your service requests. In these cases, we will act as a data processor and this Privacy Policy will not apply to such personal information. Please contact the relevant customer directly if you have questions regarding their data collection practices or any communications you may receive from them.
Blogs and Public Features of the Sites. Some of our Sites offer publicly accessible blogs or community forums. You should be aware that any personal information you submit there can be read and collected by other users of these forums and could be used to send you unsolicited messages and for other purposes. Our blog is managed by a third-party application that may require you to register to post a comment. We do not have access to or control of the information posted to the blog. None of the information that you provide using these features is protected by this Privacy Policy. We are not responsible for the personal information you choose to submit in these forums or the use thereof by any third party. You will need to contact or log into the third-party application if you want the personal information that was posted in the comments section removed. To learn how the third-party application uses your information, please review their privacy policy.
Social Media Widgets. Our Sites include buttons that allow you to share content on the Sites through services provided by Facebook, Twitter, and LinkedIn. Facebook, Twitter, and LinkedIn are social media networks not affiliated with PHRUTOS. They are headquartered at the following addresses:
Facebook: 1 Hacker Way, Menlo Park, CA 94025, USA
Twitter: 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
LinkedIn: 2029 Stierlin Court, Mountain View, CA 94043, USA
When you use the Facebook, Twitter or LinkedIn share buttons, your device will access their respective webpages and, therefore, your data will be sent to the party associated with that share button and such party may also know that you visited our Site. Further information on Facebook, Twitter and LinkedIn’s collection, use and disclosure of your personal information can be found in their respective privacy policies which can be accessed on their respective webpages.
Security. We take commercially reasonable steps to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from a Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any personal information to us or to any other party via the Internet. When you enter sensitive information (such as a credit card number) on our order forms or login credentials (such as username and password) on our platform login, we encrypt the transmission of that information using secure socket layer technology (SSL).
Retention. We will retain your information for as long as your account is active or longer if needed to provide you services, comply with our legal obligations, resolve disputes or enforce our agreements. For more information on our retention periods you can contact us here.
Minors. Visitors under 16 years of age are not permitted to use and/or submit their personal information on any Site. We do not knowingly solicit or collect information from visitors under 16 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
Data Controllers and Contacting Us. Our “contact us” page contains e-mail links that allow you to contact us directly with any questions or comments that you may have. If you have any questions about this Privacy Policy or our privacy practices or to make a complaint about our compliance with applicable privacy laws, please feel free to contact us here or at the relevant affiliates below.
Data Controller:
PHRUTOS Creative
7095 Hollywood Blvd, Mailbox 2040
Hollywood, CA 90028
United States of America
Responsible for:
PHRUTOS.com
Third party. All other activities (both online and offline)