I. SCOPE AND APPLICATION OF THE PRIVACY POLICY

This Privacy Policy applies to PHILLIO, including any services associated with PHILLIO that incorporates this Privacy Policy by reference. Those related services may have further privacy-related terms that you must agree to as part of your use of those services.

This Privacy Policy is incorporated into and forms part of the PHILLIO Terms of Service that you have agreed to in order to use PHILLIO. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the PHILLIO Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through PHILLIO; or (ii) by other companies and organizations who advertise their services on PHILLIO.

II. CHANGES TO THE PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you via PHILLIO or other means prior to the change becoming effective. By continuing to use PHILLIO after any changes to this Privacy Policy, with or without notice from us, you are agreeing to the revised Privacy Policy.

III. COLLECTING INFORMATION

In providing PHILLIO, we collect, store and use the following Information relating to you:
Personal Information may include the following:

• Information you make available to us when you open a PHILLIO account, such as your name, telephone number, place of business and/or residence and email address;
• Any information included in your publicly visible PHILLIO profile, which may include your profile ID, name and photo;
• Information you make available to us via your use of PHILLIO
• Information we collect as you use PHILLIO, such as certain Location Data and Log Data.
• The location of your device when you use PHILLIO, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device;
• The IP address of the device or internet service you use to access PHILLIO; and other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and Shared Information that you or others post which indicates your location.
• Log Datawhen you use PHILLIO, whether through the use of cookies, web beacons, log files, scripts and etags or otherwise, including:
• Technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access PHILLIO, your IP address and your device’s version and identification number;
• Information about what you have searched for and looked at while using PHILLIO, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using PHILLIO;
• Information about communications you have made using PHILLIO, such as the people you’ve communicated with and the time, data and duration of your communications; and
• Metadata, which means information related to items you have made available through PHILLIO, such as the date, time or location that a shared photograph or video was taken or posted.
• Non-Personal Information is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in any form.
• Shared Information is information about you or relating to you that is voluntarily shared on PHILLIO. Shared Information may include postings that you make on PHILLIO (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

IV. SHARING INFORMATION

You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:

• providing services to you;
• assisting us in carrying out the purposes set out under the “How We Use Your Information” section above;
• carrying out our obligations and enforcing our rights under thePHILLIO Terms of Service or this Privacy Policy; and/or
• helping us understand and improve our services.

In addition, we allow third party marketing partners to collect your Personal Information over time and across different websites or online services when you use PHILLIO.We also provide your Personal Information to third party marketing partners or Affiliates where you have asked us to do so or where it is required in order for us to provide PHILLIO to you. Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

V. AMENDING INFORMATION

If you would like to update or amend your Personal Information within PHILLIO, you may do so at first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within PHILLIO.

If you wish to make further changes to your Personal Information; request access to, or deletion of, your Personal Information from PHILLIO; or to request the removal of an unauthorized PHILLIO account, please contact our Privacy Officer. We will respond to your request within a reasonable timeframe.

If you would like to update or amend or modify your Personal Information within PHILLIO, you may do so at first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within PHILLIO.

In case if you wish to withdraw your consent for the use and disclose of your information in the manner provided in this policy or you want your data to be deleted or request for the removal of an unauthorized PHILLIO account, you are pleased to contact us at support@phillio.com and your request shall be processed within 48 hours. We also wish to inform you that we will not use your personnel data for any purpose unless required by us to comply with our legal obligations. We also wish to inform you that deletion of your account will not allow you to access our services.

VI. COMMUNICATIONS FROM US

When you use PHILLIO, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level or contacting our Privacy Officer.

VII. TRANSFER, STORAGE AND SECURITY OF INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. You consent to the transfer of your Personal Information for the purposes described in this Privacy Policy.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of Information.

In PHILLIO, we use encryption technology to protect certain sensitive Information provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access PHILLIO may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

VIII. PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will generally only retain your Personal Information for so long as is necessary to fulfill the purposes for which it was collected, as set out under the “How We Use Your Information” section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

• in order to comply with applicable laws or regulations;
• in order to comply with a court order, subpoena or other legal process;
• in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere);
• where we believe it is reasonably necessary to comply with applicable laws or regulations; or
• in order to enforce thePHILLIO Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of PHILLIO.

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in PHILLIO, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 90 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through PHILLIO, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using PHILLIO may put your Personal Information in the hands of third parties that we cannot control.

IX. TRACKING TECHNOLOGIES

We may, from time to time, use cookies, log files, web beacons, scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you.

The “tracking technologies” that we use within PHILLIO include the following:

• A cookieis a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content.
• Web beaconsare electronic image files or other technologies that may be embedded within websites or emails that may be used to keep count of visitors, record when and if an email or website is viewed, or access certain cookies.
• Certain information is automatically gathered and stored inlog files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data.
• An entity tag (orETag) are HTTP headers that are sent-behind-the-scenes between a web browser and a web server. They can be used to track unique users in place of cookies, and allow us to better understand and improve PHILLIO.
• JavaScriptis a scripting language used to produce more interactive and dynamic websites. JavaScript can create cookies, read cookies, and delete cookies.
• Anonymous identifiersare used to deliver advertisements in services where cookies may not be available (for example, in mobile applications).

We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

• Our analytics partners helps us better understand PHILLIO generally – for example, to collect website and app usage statistics and to gather demographic information about our user base as a whole, as well as to analyze any relevant trends.
• Our marketing partners (including analytics partners, advertisers and PHILLIO official account partners) help us deliver better and more relevant advertising to you.
• Our customer support service partners help us deliver better responses to any queries from you and to deliver a better PHILLIO experience to our users.
• Our service partners help us administer and deliver certain features within PHILLIO– for instance, hosting, language translation and mapping services.

It is important to note that third party tracking technologies are subject to the relevant third party’s own privacy policies and not our Privacy Policy. We are not responsible for any tracking technologies used by third parties.

If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.