1.1 Phlenu LLC (“Company,” or “we,” or “us,” or
“our”) is committed to safeguarding the privacy of our app and/or website and service users
(“users,” or “you”).
1.2 This policy applies where we are acting as a data controller with respect to your
personal data, in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Terms of Service. Use of the Company Service is subject to the terms of our Terms of
Company Service, you agree to be bound by our Terms of Service.
1.4 Your use of the Company Service is subject to the terms and conditions set forth in this
1.5 We continually strive to find new ways to enhance your experience with the Company
by email, or by means of notice through the Website, the Application, or any other part of the Company Service.
NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE COMPANY SERVICE.
2. Types and Uses of Collected Information. Company collects two types of information about
2.1 Personally Identifiable Information. Personally Identifiable Information is information
that identifies a specific person. When you engage in certain activities via the Company Service, including but not
limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively,
“Identification Activities”), we may ask you to provide certain information about yourself. If you elect
to engage in an Identification Activity we may ask you to provide us with certain personal information about
yourself, such as your name, address (including zip code), email address, credit card information, telephone number
and/or any other information you provide to us, to process your transaction, send communications about them to you,
and populate forms for future transactions. When you enroll in the Company Service, we may also ask you to provide
us with additional information, such as credit card information. Depending on the Identification Activity, some of
the information we ask you to provide may be identified as mandatory and some identified as voluntary. If you do not
provide mandatory information for an Identification Activity, you will not be permitted to engage in that
Identification Activity with the Company Service. Depending on the Identification Activity, Company might not re-ask
you for Personally Identifiable Information if such are already stored with us. If you enroll in the Company Service
through a third party (such as Facebook or Google) then Company may receive Personally Identifiable Information from
such third party and by using the Company Service, you consent to such receipt of Personally Identifiable
Information to provide products and/or services to you, to enable Third-Party advertisers to provide products and/or
services to you, administer sweepstakes and contests, enhance the operation of the Company Service, improve our
marketing and promotional efforts, analyze use of the Company Service, improve the Company Service, and tailor your
Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements
2.2 Non-Personally Identifiable Information. Non-Personally Identifiable Information is
information that does not identify a specific person. This type of information may include things like the Uniform
Resource Locator (“URL”) of the website you visited before coming to the Company Service or otherwise
participating in the Company Service, the URL of the website you visit after leaving the Company Service, the type
of browser you are using, your Internet Protocol (“IP”) address, mobile carrier information, mobile
device information, or general and/or aggregated location data that does constitute Personally Identifiable
Information. We, and/or our authorized Third-Party Service Providers, may automatically collect this information
when you visit or use the Company Service using electronic tools like Cookies and Web beacons or Pixel tags, as
device identification and mobile device type, the request type, your mobile carrier, your mobile carrier user
identification, and the content of your request, does not by itself identify you to Company, though it may be unique
or consist of or contain information that you consider personal. We use Non-Personally Identifiable Information to
troubleshoot, administer the Company Service, analyze trends, gather demographic information, comply with applicable
law, and cooperate with law enforcement activities. We may also share this information with our authorized
Third-Party Service Providers to measure the overall effectiveness of our products and services.
3. How we use your personal data.
3.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”).
The usage data may include your IP address, geographical location, browser type and version, operating system,
referral source, length of visit, page views and website navigation paths, as well as information about the timing,
frequency and pattern of your service use]. The source of the usage data is our analytics tracking system. This
usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for
this processing is your consent or our legitimate interests, namely monitoring and improving our website and
3.3 We may process your account data (“account data”). The account data may include
your name and email address. The source of the account data is you. The account data may be processed for the
purposes of operating our website, providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your
consent or our legitimate interests, namely monitoring and improving our website and services.
3.4 We may process your information included in your personal profile on our website
(“profile data”). The profile data may include your name, address, telephone number, email address,
profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our
website and services. The legal basis for this processing is your consent or our legitimate interests, namely
monitoring and improving our website and services.
3.5 We may process information that you post for publication on our website or through our
services (“publication data”). The publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis for this processing is your consent or our
legitimate interests, namely monitoring and improving our website and services.
3.6 We may process information contained in any inquiry you submit to us regarding goods
and/or services (“inquiry data”). The inquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent or
our legitimate interests, namely monitoring and improving our website and services.
3.7 We may process information relating to transactions, including purchases of goods and
services, that you enter into with us and/or through our website (“transaction data”). The transaction
data may include first and last names, an email address to be used as a login, billing contact information, credit
card number and a password. The transaction data may be processed for the purpose of supplying the purchased goods
and services and keeping proper records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and
our legitimate interests.
3.8 We may process information that you provide to us for the purpose of subscribing to our email notifications
and/or newsletters (“notification data”). The notification data may be processed [for the purposes of
sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or
our legitimate interests, namely monitoring and improving our website and services.
3.9 We may process information contained in or relating to any communication that you send to us
(“correspondence data”). The correspondence data may include the communication content and metadata
associated with the communication. Our website will generate the metadata associated with communications made using
the website contact forms. The correspondence data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring
and improving our website and services.
3.10 We may process any of your personal data identified in this policy where necessary for the establishment,
exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal
rights, your legal rights and the legal rights of others.
3.11 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we
may also process any of your personal data where such processing is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests or the vital interests of another natural
3.12 Please do not supply any other person’s personal data to us unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our
ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal
bases, set out in this policy.
4.2 Financial transactions relating to our website and services may be handled by our payment services providers. We
will share transaction data with our payment services providers only to the extent necessary for the purposes of
processing your payments, refunding such payments and dealing with complaints and queries relating to such payments
4.3 We may disclose your inquiry data to one or more of those selected third-party suppliers of services via APIs
identified on our website for the purpose of enabling them to connect your account with their Services. Each such
third party will act as a data controller in relation to the inquiry data that we supply to it. Each such third
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal
data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural person. We may also disclose your
personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure. We may use Third Party Service Providers to
serve ads when you participate in the Company Service. These companies may use Non-Personally Identifiable
Information about your visits and use of the Company Service, and visits to other websites or locations to provide,
through the use of network tags, advertisements about goods and services that may be of interest to you.
5. About cookies
5.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a
web browser and is stored by the browser. The identifier is then sent back to the server each time the browser
requests a page from the server.
5.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be
stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the
expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser
5.3 Cookies do not typically contain any information that personally identifies a user, but personal information that
we store about you may be linked to the information stored in and obtained from cookies.
preventing fraudulent use of login credentials, and to protect our website and services generally.
6. Cookies used by our service providers
6.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use
by means of cookies. The information gathered relating to our website is used to create reports about the use of our
7. Managing cookies
7.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from
browser to browser, and from version to version. You can however obtain up-to-date information about blocking and
deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete -manage-cookies (Internet
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
7.2 Blocking all cookies will have a negative impact upon the usability of many websites.
7.3 If you block cookies, you will not be able to use all the features on our website.
8. Security of Information?. You can access your Personally Identifiable Information via the Company Service with
your password and username. This password is encrypted. We advise against sharing your password with anyone. If you
access your account via a third-party site or service, you may have additional or different sign-in protections via
that third-party site or service. You need to prevent unauthorized access to your account and Personal Information
by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your
computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized
entry or use, hardware or software failure, and other factors, may compromise the security of user information at
any time. If we believe that the security of your information may have been compromised, we may seek to notify you
of that development. In addition, your Personally Identifiable Information resides on a secure server that only
selected personnel and contractors have access to. We may encrypt certain sensitive information using Secure Socket
Layer (SSL) technology to ensure that your Personally Identifiable Information is safe as it is transmitted to us.
However, no data transmission can be guaranteed to be 100% secure. As a result, while we employ commercially
reasonable security measures to protect data and seek to partner with companies that do the same, we cannot
guarantee the security of any information transmitted to or from or via the Company Service, and we are not
responsible for the actions of any third parties that may receive any such information.
9. Analytics We continuously improve our websites and our products, and we utilize different third-party web
analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, our mobile
applications, what they like and dislike, and where they have problems. Our products, desktop tools and mobile
applications use analytical tools to understand feature usage patterns, to enhance and improve your product
experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as
to increase functionality and enhance your user experience, this usage information may be linked to personal
information that we have about individual users. We maintain ownership of this data and we do not share this type of
data about individual users with third parties. This information is used solely to assist us in maintaining a more
effective and useful websites and products for our customers. This data will not be shared with third parties
without your prior consent or unless required by law.
10. Security We are committed to taking all reasonable precautions to safeguard the privacy of personal information
which has been provided by its users. We use technical, contractual, administrative and physical security steps to
protect your personal information. Security measures such as restricted access and the use of passwords and
encryption have been adopted to protect your personal information against loss or theft, as well as unauthorized
access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all
times and those employees with access to your personal information shall use your personal information strictly in
encryption technology. Please be aware that no data transmission over the Internet or via e-mail is completely
secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot
guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will
not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the
security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit
card number, you should not send it electronically unless the email is encrypted or your browser indicates that the
access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public,
not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and
may result in unsolicited messages from other parties.
11. Your rights
11.1 In this Section we have summarized the rights that you have under data protection law. Some of the rights are
complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant
laws and guidance from the regulatory authorities for a full explanation of these rights.
11.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
11.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access
to the personal data, together with certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can
access your personal data by visiting your profile when logged in.
11.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the
purposes of the processing, to have any incomplete personal data about you completed.
11.5 In some circumstances you have the right to the erasure of your personal data without undue delay, and at the
latest within one month of receiving your valid request. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing under certain rules of applicable data protection
law; the processing is for direct marketing purposes; and the personal data have been unlawfully process. However,
there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the
establishment, exercise or defense of legal claims.
11.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer
need the personal data for the purposes of our processing, but you require personal data for the establishment,
exercise or defense of legal claims; and you have objected to processing, pending the verification of that
objection. Where processing has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or
defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of
important public interest.
11.7 You have the right to object to our processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
the performance of a task carried out in the public interest or in the exercise of any official authority vested in
us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise
or defense of legal claims.
11.8 You have the right to object to our processing of your personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data
for this purpose.
11.9 You have the right to object to our processing of your personal data for scientific or historical research
purposes or statistical purposes on grounds relating to your particular situation, unless the processing is
necessary for the performance of a task carried out for reasons of public interest.
11.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take
steps at your request prior to entering into a contract, and such processing is carried out by automated means, you
have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.11 If you consider that our processing of your personal information infringes data protection laws, you have a
legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the
EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11.12 To the extent that the legal basis for our processing of your personal information is consent, you have the
right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the
withdrawal. 12. Children. The Company Service are not directed to people under the age of eighteen
(18). If you become aware that your child has provided us with personal information without your consent, please
contact us at the email address listed below. If we become aware that a child under the age noted above has provided
us with personal information, we take steps to remove such information and terminate the child’s account.
13. Retaining and deleting personal data
13.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we
comply with our legal obligations in relation to the retention and deletion of personal data.
13.2 Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request
for deletion from you.
13.3 Notwithstanding the other provisions of this Section we may retain your personal data where such retention is
necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital
interests or the vital interests of another natural person.
14. Notice of Privacy Rights to California Residents?. California law requires that we provide you with a summary of
your privacy rights under the California Online Privacy Protection Act (“COPPA”) and California
Business and Professions Code. As required by COPPA, we will provide you with the categories of Personally
Identifiable Information that we collect through the Company Service and the categories of third party persons or
entities with whom such Personally Identifiable Information may be shared for direct marketing purposes at your
request. California law requires us to inform you, at your request,
(1) the categories of Personally Identifiable Information we collect and what third parties we share that information
(2) the names and addresses of those third parties; and
(3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you
do not want us to share that information with. To obtain this information, please send a request by email or
physical mail to the address found below. When contacting us, please indicate your name, address, email address, and
what Personally Identifiable Information you do not want us to share with our marketing partners. The request should
be sent to the attention of our legal department and labeled “California Customer Choice Notice.” Please
allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your
Personally Identifiable Information or requesting this notice.
15. Request to delete an account : You can request to delete an account on phlenu app if you have signed up/ Signed In using Google, Facebook, Apple or App sign up. In order to delete your account from the Phlenu platform, please send the request to firstname.lastname@example.org, your account shall be removed in 7 working days.
16. Who can I ask if I have additional questions? For additional inquiries about the privacy of your information, you
can contact us by emailing us at ?email@example.com?.