Privacy Policy

_{01 · Introduction}

Introduction

Phave, Inc. ("Phave," "us," "we," or "our") operates the phave.com website, applications and social media sites to provide products and services offered by Phave (hereinafter referred to as "Service").

Our Privacy Policy governs your visit to phave.com and your use of the Service, and explains how we collect, use and disclose information that results from your use of our Service. We use your data to provide and improve the Service. By using the Service, you agree to the collection, use and sharing of your Personal Data in accordance with this Privacy Policy.

_{02 · Definitions}

Definitions

"Personal Data" means (a) any information, in any form, that identifies, or in combination with other information may identify, an individual, and (b) any information which would qualify as "personally identifying information," "personal data," or "personal information" under applicable privacy laws.

_{03 · Rights}

Your Rights

You have the following data protection rights:

01 - Access

You can request copies of your personal information.

02 - Rectification:

You can request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

03 - Erasure:

You can request that we erase your personal information, under certain conditions.

04 - Restrict processing:

You can request that we restrict the processing of your personal information, under certain conditions.

05 - Object to processing:

You can object to our processing of your personal information, under certain conditions.

06 - Data portability:

You can request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

If you wish to exercise any of these rights, please contact us at privacy@phave.com.

_{04 · CCPA}

California Consumer Privacy Act (CCPA) Compliance

If you are a California resident, you have specific rights under the CCPA regarding your personal information:

• Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
• Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
• Right to Opt-Out: If Phave sells personal information, you have the right to opt-out of that sale.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise these rights, please contact us at privacy@phave.com.

_{05 · Your Choices}

Your Choices

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

_{06 · Collection}

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you, as further detailed below.

Personal Data & Information You Provide to Us

While using our Service, we may ask you to provide us with Personal Data. Personal Data may include, but is not limited to:

• Account Information, such as email address, first name and last name, company name and company business address;
• User Uploaded Content; and
• Usage Data.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you regarding the Services or other Phave products and services. We will only send you such marketing communications if you opt-in to receiving them. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us directly at privacy@phave.com.

User Uploaded Content

In connection with using our Services, you may upload content ("User Uploaded Content"). User Uploaded Content may include content containing Personal Data. Additionally, any User Uploaded Content may include metadata related to the content. This metadata may also contain Personal Data. By uploading User Uploaded Content, you permit us to collect, process and store your User Uploaded Content. You can delete the User Upload Content from your account at any time.

Other Information You Submit

You may submit Personal Data to us for limited purposes, such as requesting customer support, providing feedback on our Service, or signing up to receive communications from us.

Usage Data

We may also automatically collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device including information about when and how you visit and interact with the Services, what webpages you accessed, and your interaction with website features ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Where you access the Services and log in from multiple devices, we will be able to use your account information to identify your activity across devices.

_{07 · Cookies}

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. We use cookies and other technologies to passively collect demographic information, personalize your experience on our site and monitor advertisements and other activities. We may link cookie information to Personal Data to track pages you have viewed; to customize your experience, ads, content or offers of our Services; to conduct market research and measurement in order to improve our Services and to make our Services more useful for users.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent.

If you are based in Europe, visit www.youronlinechoices.eu for more details about advertising cookies and their management.

If you are in the US, refer to www.aboutads.info/choices/. Visit www.allaboutcookies.org/manage-cookies to enable/disable cookies. Disabling cookies that are necessary for the website's proper operation may result in the web page not loading, or not operating as expected. Disabling cookies that remember your preferences or analytics will prohibit us from providing you with relevant information. If you disable all cookies (including the essential ones), then you won't be able to access all parts of our website.

Examples of Cookies we use

• Session Cookies: We use Session Cookies to operate our Service.
• Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
• Security Cookies: We use Security Cookies for security purposes.
• Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Information From Other Sources

We may receive information about you from other sources and add it to our information. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.

Customer Data

This Privacy Policy does not apply to the practices of third parties that Phave does not own or control, or to individuals that Phave does not employ or manage.

Furthermore, this Privacy Policy does not apply to any third party information gathered by subscribers to Phave's Service (i.e., information about customers of Phave subscribers) and submitted by them to the Service for use in connection with their activities ("Customer Data"). Phave will not review, share, distribute, print, or reference any such Customer Data except as provided in the Service Agreement or as may be required by law.

_{08 · Use of Data}

Use of Data

Phave uses the collected data for various purposes:

• To verify your identity when you access your account or Services.
• To provide, maintain and improve our Service.
• To notify you about changes to our Service.
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve our Service.
• To customize your user experience.
• To monitor the usage of our Service.
• To detect, prevent and address technical issues.
• To detect, investigate and prevent security threats or incidents.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about to the extent that you have opted-in to receive such communications.
• To prevent our Services from being used to distribute spam, disseminate prohibited or fraudulent content, or from being used to threaten the safety of others.
• To enforce violations of our Terms of Service and other usage policies; to protect and defend our rights or property; to prevent fraud or abuse; to prevent or investigate fraud or other unauthorized, illegal, or wrongful activity; and to protect the personal safety of users or others.
• To comply with our legal obligations, including responding to legal requests (e.g., court or government agency order, subpoena, etc.), to resolve disputes and enforce agreements.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also process your personal data when we have a legitimate interest in doing so. This means that we have a business or commercial reason to use your information. We will only do this when our interests are not overridden by your data protection rights. Our legitimate interests include:

• Improving and personalizing our services
• Protecting our business and our customers from fraud and other illegal activities
• Ensuring network and information security

We may aggregate and/or anonymize information collected through the Services so that such information does not identify you as the source of the information. We use such aggregated and/or anonymized data for machine learning to support and improve certain product features and functionality within the Service.

_{09 · Retention}

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If your account is deleted, deactivated or terminated, your Personal Data will be deleted within sixty (60) days from termination or deactivation.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

_{10 · Transfers}

International Transfers of Data

Phave is based in the United Stated but operates globally. Your Personal Data is processed at our operating offices and in any other locations where the service providers are located. Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. By using the Services or providing your Personal Data to us, you acknowledge and consent that your Personal Data may be collected, processed, or transferred outside your country.

Phave will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, including, for instance, by entering into the appropriate data processing agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators.

_{11 · Disclosure}

Disclosure of Data

We may disclose your Personal Data to:

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, law enforcement, governmental agencies, or regulators.

Business Transaction

If Phave, or substantially all of its assets, were acquired, or in the unlikely event that Phave goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Phave may continue to use your personal information as set forth in this policy.

Service Providers: We may share your Personal Data with third party vendors (or subprocessors) (collectively "Service Providers") that help us operate our Services, permit us to administer your account, process orders, and help us fulfill our contractual obligations. These Service Providers have access to your Personal Data only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.

International Transfers of Data

Your information, incuding Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Phave will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Analytics

We use third-party analytics services to help us monitor and analyze how our Services and features are being used.

In connection with these analytics services, we may disclose the following categories of Personal Data to analytics service providers:

• Identifiers: Email addresses used for customer login
• Internet or Electronic Network Activity: URLs visited within our Services, features used, interaction data, and timestamps
• Device Information: IP addresses, browser type, and device identifiers

These service providers are contractually prohibited from using your Personal Data for any purpose other than providing analytics services to us and may not share your information with other parties.

To opt out of use of third party cookies that share data with these analytics providers, follow the steps described in Section IV of this Policy.

Other Cases

We may disclose your information also:

• To our subsidiaries and affiliates.
• For the purpose of including your company's logo on our website;

We share your Personal Data with persons whom you have granted account-level access. We may also make your Personal Data available to others as you direct us to do in connection with your use of the Services.

We may also share your Personal Data with third parties where we have obtained your express consent to do so.

_{12 · Security}

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Furthermore, we are not responsible for any breach of security or for any actions of any third parties that receive the Personal Data.

_{13 · Third-Party Sites}

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We do not have control over and assume no responsibility for the content, the information collection practices by third party application platforms or third party websites or their privacy policies. We therefore strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

_{14 · Communications}

Communications from Us

You may receive commercial emails from us if you have opt-in to receive such communications. At any time, you may opt-out from receiving commercial messages by following the unsubscribe instructions at the bottom of such messages. Please note that opt-out requests may take several days to process. You will continue to receive transactional emails.

We may receive a confirmation when you open an email from Phave if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful and improve our service. If you do not want to receive e-mail or other mail from us, please notify us by e-mail at privacy@phave.com or by unsubscribing through the unsubscribe or opt-out link in an email.

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_{15 · Children}

Children's Privacy

Our Services are not intended for use by children under the age of 18 ("Child" or "Children").

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us at privacy@phave.com. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

_{16 · Changes}

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

_{17 · Contact}

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@phave.com.