Last updated: 08/15/2019.
70 Willow Road, Suite 200
Menlo Park, CA 94025
Attn: General Counsel
A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If we discover that a child under 13 has submitted Personal Data to Phathom, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at firstname.lastname@example.org
3. A Note to Users Outside of the United States. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding the processing of Personal Data may be less protective than the laws in your country. By providing your data, you consent to such processing and transfer.
4. Types of Data We Collect. “Personal Data” means data that, by itself, allows someone to identify or contact you as an individual, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that does not, by itself, permit the identification of individual persons and that is not associated with or linked to Personal Data. We collect Personal Data and Anonymous Data, as described below.
(a) Information You Provide to Us.
If you provide us feedback or contact us via e-mail, we will collect your name, title, e-mail address, and any other content included in your e-mail to us, in order to send you a reply. If you choose to provide us with Personal Data, you consent to the transfer and storage of that information on our servers.
We will also collect Personal Data at other points in our Site that state that Personal Data is being collected.
(b) Information Collected via Technology.
Information Collected by Our Servers. To make our Site more useful to you, our servers (which may be hosted by a third-party service provider) may collect information from your computer or device, including but not limited to:
The date and time of your visit and the web pages, content, and advertisements you view and links you click on while navigating within our Site;
Information about the type of content accessed via our Site;
The site you visited before and after visiting our Site;
Your Internet Protocol (IP) address (a numerical address assigned to your computer by your Internet service provider so that other computers connected to the Internet can communicate with your browser online) that can sometimes be used to derive your general geographic area;
Search terms you enter on a referral site;
Information about your device such as your device type, browser type, language and other settings, memory capacity, plug-ins, Internet domain, advertising identifiers, TCP configuration parameters, operating system, time zone and the names, versions and package IDs of software installed on your device; and
Information collected through cookies and other tracking technologies (see additional descriptions of these terms below).
Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, that are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages.
Do Not Track. We do not currently respond to “do not track” signals from web browsers.
5. Use of Your Personal Data
(a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, aid us in serving you better, and improve our Site. We and our authorized service providers may use your Personal Data in various ways, including to:
provide improved administration of our Site, diagnose problems with the servers and equipment used in connection with the Site and gather broad demographic data;
measure and analyze audience traffic and improve the quality of your experience when you interact with our Site and our services;
contact you to follow up on a request you made;
prevent potentially prohibited or illegal activities, comply with applicable law, and enforce the terms of any agreements we may have with you; and
for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
(a) Third-Party Service Providers. We may share your Personal Data with third-party service providers that conduct quality assurance testing, provide technical or customer support, and/or provide other services to Phathom, including to assist us in analyzing how our Site is used.
8. Your Choices Regarding Information. You have several choices regarding the use of information on our Service:
(a) Cookies. If you decide at any time that you no longer wish to accept Cookies for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Site or all functionality of the Site. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
(b) Google Analytics. You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout/.
(c) Accessing, Changing or Deleting Your Personal Data. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.
9. Risk of Disclosure. No Internet transmission is ever 100% secure or error-free. More specifically, information transmitted to or from the Site may not be via a secure connection. As a result, you should take particular care in deciding what information you send via our Site.
10. Retention. We will retain your Personal Data as long as necessary to provide you the services offered there through and the other permitted uses specified herein, and for a reasonable transition time thereafter. We may store Anonymous Data (i.e., information that is not Personal Data) indefinitely.