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PRIVACY POLICY

At PHIDAL INC.. (“PHIDAL”), we value you and respect your privacy. PHIDAL recognizes that it must maintain and use your personal information responsibly. We have created this privacy policy (the “Policy”) to demonstrate our firm commitment to your privacy and security, and to advise you about the collection, use and disclosure of personal information provided by you by telephone, through the Site, by mail or other means (electronic or otherwise). PHIDAL will not collect, use or disclose your personal information other than in compliance with this Policy.

By providing any of your personal information to PHIDAL, including information obtained by us during your visits to or use of the website, other PHIDAL sites or microsites, social networking websites and web pages such as Facebook, Twitter, Instagram, YouTube or any other online site on which PHIDAL maintains a presence in connection with PHIDAL’s activities (collectively, the “Site”), you hereby agree to all of the terms and conditions of this Policy and consent to the collection, use and disclosure of your personal information as described in this Policy.  Please note that except as is set forth in this Policy, we reserve the right to share anonymized and/or aggregated data acquired by us through your provision of your personal information with third parties.

The terms “we”, “us”, and “our” used in the Policy refer, collectively, to PHIDAL and its departments, divisions, and their respective employees, mandataries, agents and other representatives (collectively, “PHIDAL Organization”).

Contents

WHAT IS “PERSONAL INFORMATION”?

WHAT INFORMATION IS COLLECTED BY PHIDAL?

HOW IS MY PERSONAL INFORMATION COLLECTED?

HOW IS MY PERSONAL INFORMATION USED?

TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?

PERSONAL INFORMATION OUTSIDE OF CANADA

THIRD PARTIES & THIRD PARTY WEBSITES

HOW DOES PHIDAL STORE AND SAFEGUARD MY INFORMATION?

WHAT IS “PHISHING”?

CHILDREN

HOW DOES PHIDAL MANAGE CONSENT, AND HOW DO I EXERCISE MY CHOICES?

HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?

CONTACTING US

 

WHAT IS “Personal Information”?

“Personal information” is any information that identifies, or could be reasonably associated with, an individual (“individual” or “you”). This may include, for example, your name, contact information, email-address, and information relating to your account with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

 

WHAT INFORMATION IS COLLECTED BY PHIDAL?

Personal information we collect may include:

  • Identifiers and contact information, such as your name, email and postal addresses, telephone number, photographs or videos or account information if you have created an account upon signing up);
  • Demographic information and interests, such as your age, gender, language, types of activities you participate in and other interests;
  • Transactional information, such as bank account information, payment card details,
  • Browsing activity on our Site, such as pages and events viewed, clickstream data, account login events, preferences, and IP addresses if it can identify you as an individual;
  • Geolocation information collected when you use our Site;
  • Any other information you provide to us.

HOW IS MY Personal Information COLLECTED?

  • Directly from you

We will also collect personal information from you when you provide information to us, such as by completing an entry form, ballot or survey, by communicating with us by telephone, e-mail or otherwise, by setting up a user account and password, logging in as a registered user of the Site and providing information in your account(s), or by introducing or post any text, image, video, audio, or any information, content or other materials through any of PHIDAL social networking websites and web pages such as Facebook, Twitter, Instagram or YouTube. As a result of these actions, you might supply us with personal information, such as your name, date of birth, e-mail and postal addresses, telephone number(s), credit card information and financial information and in certain circumstances, your comments, suggestions, ideas, opinions and individual preferences.

  • Through Online Technologies

Each time you visit the Site, the following information may automatically be obtained and compiled: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and hardware platform you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing the Site; your entire query (if any) that was entered into a search engine which led you to the Site; and any other “click stream” data. This information may be stored in our log files.

Additionally, the complete record of your actions at the Site, including all pages visited, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded is collected. This tracking information may be compiled by us in the aggregate and be made available to third parties in order to identify demographic data regarding our users.

The technologies we use may include:

  • Cookies, which are small data files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our Site. In certain cases, this information is only kept during the session and is deleted when you close your browser. In other cases, the information is stored on your hard drive and, upon your next visit to the Site, the cookies are used to recall such information.  Cookies may store a variety of information, including, a unique user ID that can be used to track the pages of the Site you have visited and the number of times that you view a particular page or other item on the Site, login or registration information and your preferences and your transaction history, where available.
  • Web beacons and pixels, which are techniques used to track who is visiting a web page or has opened an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
  • Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization or customization of content and other methods to gain insights into our customers’ needs and preferences.

 

  • Third Party Social Networks

PHIDAL has installed on the Site various social media plug-in protocols, such as Facebook’s “Like” button, which allow you to share your likes and interests in PHIDAL products with your friends and contacts. When you use one of these social media plug-in protocols, PHIDAL will have access to this information as well.

Facebook and other third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to Facebook) on the Site may use cookies to gather information on your use of the Site. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. PHIDAL encourages you to review the privacy policies of such third parties as well.

We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content PHIDAL promotes.

 

HOW IS MY PERSONAL INFORMATION USED?

We use your personal information for the following purposes:

·      Providing Programs and Services

We use your personal information in order to provide programs and services, such as:

  • Verifying your identity;
  • Processing your transactions and providing receipts;
  • Allow you to participate in features we offer or to provide related customer service;
  • Taking or verifying instructions from you;
  • Creating, administering, and maintaining your accounts; and
  • Fulfilling your requests and responding to your inquiries.

·      Managing Our Operations

We use your personal information to manage our operations, for instance:

  • Deploying and managing our information technology applications and systems, including managing our Site;
  • Notifying you of changes to our services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
  • Maintaining the security of the public, our users and our employees;
  • Protecting ourselves and third parties from errors and fraud;
  • Maintaining our services; and
  • Meeting our contractual, legal and regulatory obligations.

·      Marketing

We use your personal information to inform you about our products, sales, raffles, sweepstakes, contests, promotions, events, surveys or initiatives offered by PHIDAL We may do this by communicating with you in a variety of ways, such as by email, telephone, direct mail, or through social media.

If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. For more information on managing your preferences, please see “How does PHIDAL Manage Consent, and How Do I Exercise My Choices?”, below.

·      Conducting Research and Analytics

We may use your personal information in order to conduct research and data analytics by tracking and analyzing current or previously collected information for the following purposes:

  • Improving or developing new services;
  • Managing and developing our operations;
  • Understanding our customers’ interests and priorities
  • Understanding how visitors interact with our Site and ensuring it works correctly.

When possible, we will use your information in an aggregated and/or de-identified format.

In order to better serve you, we may combine information you provide to us either in person, online, by telephone or in writing for any purpose. We may also combine your information with readily available demographic information in order to enable us to communicate with you, by telephone (including by way of automated dialing answering device) e-mail, mail or other electronic means about our services, surveys, events and other initiatives.

 

TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?

We will not disclose your personal information to any non-affiliated third party without your prior consent, other than as provided below:

  • We may disclose your personal information within or among the divisions PHIDAL, so that different divisions may communicate with you (whether by e-mail, telephone, post or otherwise) and provide you with promotional materials and additional information about its services, or collect and use that information subject to and for other purposes contemplated by this Policy.
  • We may transfer personal information to non-affiliated third party service providers for processing on our behalf (such as fulfillment services, technical support, delivery services and financial institutions) We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and adhere to confidentiality as well as security procedures and protections.
  • We may decide to transfer all or part of our operations or activities to a third party, to merge with another entity, or to engage in another form of legal transaction. If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with applicable privacy legislation in Canada.
  • Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect the property, interests and rights of PHIDAL and any PHIDAL Affiliates, our employees, or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.

Other than as listed above, we may, with your implied or express consent, share or disclose your personal information outside of PHIDAL, in accordance with applicable laws.

 

PERSONAL INFORMATION OUTSIDE OF THE UNITED STATES

Your personal information may in some cases be transferred to jurisdictions outside the United States, to service providers or affiliated organizations. As a result, you understand that your personal information will be subject to the laws of other jurisdictions than the United States and may be available to foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in accordance with applicable data protection laws and this Policy.

 

THIRD PARTIES & THIRD PARTY WEBSITES

Third parties that you connect with directly through hyperlinks or other information provided on our Site may collect, use or disclose your personal information, or link and combine information about you to other personal information they may have collected on you, to achieve their own goals and purposes.

When personal information is collected by any such third parties, PHIDAL does not collect, use or disclose such information, which is subject to the privacy policies of the third party organization. We do not control the collection, use or disclosure of such personal information and PHIDAL encourages you to review the privacy policies of such third party organizations.

In certain cases, PHIDAL may have entered into a joint venture or partnership, or other form of participatory interest, with other organizations to provide certain platforms or services; for the purposes of this Policy, such joint ventures, partnerships or interests are also third parties to PHIDAL and are not included in the Site, except to the extent that PHIDAL is using that platform or service to provide PHIDAL services, or initiatives.

 

HOW DOES PHIDAL STORE AND SAFEGUARD MY INFORMATION?

We have adopted physical, technological and organizational processes and procedures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used.

We will store your personal information for as long as necessary to fulfill the purposes for which it was collected and in accordance with PHIDAL’s automatic computer back-up procedures and document retention policies, except where otherwise required or permitted by law.

 

 WHAT IS “PHISHING”?

“Phishing” is a scam designed to obtain personal information. If you receive an e-mail which appears to be from PHIDAL requesting any personal information, please do not respond. We do not request any personal information by e-mail.

 

 CHILDREN

In light of the importance of protecting children’s privacy, we do not seek to purposely collect, process or use on the Site any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent or other legal representative. If a parent or guardian discovers that his or her child has provided us with personally identifiable information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records.  In such a case we ask that the parent or guardian of the child contact us at the contact information provided in the “Contacting Us” section below for such purpose.

 

HOW DOES PHIDAL MANAGE CONSENT, AND HOW DO I EXERCISE MY CHOICES?

By accessing the Site or responding to surveys or emails you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, your consent may be “implied”, i.e., your action or inaction at the point of collection, use or sharing of your personal information is interpreted as evidence of consent.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Policy. Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us.

If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, you may not be able to use, obtain or participate in the information that you requested or that could be offered to you.

In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may subsequently withdraw your consent at any time, subject to legal or regulatory requirements or contractual obligations and reasonable notice, by contacting our privacy officer in the manner described in the section entitled “Contacting us” below. Our privacy officer will also be able to provide you with more information regarding the implications of withdrawing consent.

In respect of requests not to receive promotional communications from us, you may withdraw consent by following the “unsubscribe” instructions provided in any promotional communications sent to you, or by contacting us in the manner described in the section entitled “Contacting us” below. It may take up to ten (10) days to process your request, during which period you may continue to receive communications from PHIDAL.

We use technologies to manage your interactions with our Site and to enhance your experience, such as cookies.  You may delete or disable certain of these technologies via your browser. Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device. We may also use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behavior as you visit our Site. You can manage your privacy preferences with respect to certain third parties by using the functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our Site.

 

HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?

You are entitled to request access to, and, if necessary, correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see “Contacting us” below). It is your responsibility to provide accurate, correct and complete information.

You can also contact our privacy officer for any questions about or to make any complaint in relation to this Policy, as well as PHIDAL’s privacy practices in general (see the “Contacting us” section below).

PRIVACY POLICY CHANGES

If we decide to change our Policy, we will post these changes on the Site so that you can be updated as to what information we gather, how that information may be used and whether (and how) it may be disclosed to any third parties. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to use our services after the modified version of the Policy has been posted or you have been informed of such update, you agree to be bound by all such changes unless you advise us in writing, by phone or by e-mail that you wish to withdraw your consent in accordance with the procedures provided in this Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop using our services. It is your obligation to regularly review this Policy to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the bottom of the Privacy Policy indicates when it was last updated.

CONTACTING US

If you have any questions about how we handle your personal information, please contact us as indicated below.

 

By E-Mail: privacy@phidal.com  –  By Phone: 786-288-0339  –  By Post Mail: Privacy Officer 20900 NE 30th Avenue Suite #407, Aventura, Florida 33180

Effective Date: January 2021