Welcome to the website (the “Site” ) of Phaidra, Inc. (“Phaidra,” “we,” “us,” or “our” ). We have prepared this Privacy Policy to explain what personal information that we collect, how we use and share that information, and your choices concerning our information practices in connection with our products and services (the “Service” ).

Before using the Service or submitting any personal information to Phaidra, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

Personal Information We Collect

Personal Information You Provide: We collect the following categories of personal information from you when you interact with the Site and/or use the Service:

• Identification Information: We collect your name, email address, phone number, mailing/billing addresses, place of business, and other similar information that you voluntarily provide to us.

• Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.

• Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.

• Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

Cookies

We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect personal information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

How We Use Personal Information

We may use personal information for the following purposes:

• To provide you with the Service, including to respond to your inquiries, comments, feedback, or questions;

• To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;

• To analyze how you interact with our Service;

• To maintain and improve the Service;

• To develop new products and services;

• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and

• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated Information

We may aggregate personal information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing

We may use your personal information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. If at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

Sharing and Disclosure of Personal Information

Phaidra does not sell your personal information. In certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.

• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.

• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.

• Affiliates: We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Phaidra. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.

Data Retention

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

Children

Our Service is not directed to children who are under the age of 18. Phaidra does not knowingly collect personal information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided personal information to Phaidra through the Service please contact us and we will endeavor to delete that information from our databases.

Security

We implement appropriate security measures to protect personal information both online and offline from loss, misuse, unauthorized access, disclosure, or alteration. Please note that no service is completely secure. Please keep this in mind when disclosing any personal information to Phaidra via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

California Privacy Rights Disclosures

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

• To know the categories of personal information that Phaidra has collected about you, the business purpose for collecting your personal information, and the categories of sources from which the personal information was collected;

• To access the specific pieces of personal information that Phaidra has collected about you;

• To know whether Phaidra has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information;

• To have Phaidra, under certain circumstances, delete your personal information;

• To instruct businesses that sell personal information to stop doing so - Phaidra, however, does not sell personal information; and

• To be free from discrimination related to the exercise of these rights.

If you would like to exercise any or all of these rights, you may do so by contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Please contact us with questions or to request access to an alternative format of this Privacy Policy.

International Users

Our Service is based in the United States. By using our Service, you understand and acknowledge that your Personal Data will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction.

Your Choices

In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to request updates or corrections to your personal information.

Changes to the Privacy Policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

GDPR Overview

The purpose of GDPR is to protect the private information of EU citizens and give them more control over their personal data. Under GDPR, private information is defined as any information that is directly or indirectly identifiable to an individual. This includes information such as social security numbers, location data, online identifiers, pseudonymous data, and genetic or biometric data, such as fingerprints and facial recognition.

Specifically, GDPR grants EU citizens these controls over their personal data:

• Right of access: Data controllers will be required to fulfill requests from individuals seeking access to their private data or information on how it is being used. Data collectors and processors will have to detail how the personal information was obtained, how and why it is being used, as well as with whom the company is sharing the information. Companies will also be mandated to provide the individual with a copy of their personal records.

• Notice of security breaches: Individuals must be alerted within 72 hours if their personal data has been hacked or otherwise compromised.

• “Right to erasure”: Individuals can decide they no longer want their personal data to be processed and request that all of their information be deleted.

• Data portability: Individuals will be permitted to move their personal data from one company to another upon request, without opposition from the data controller.

CCPA Overview

The California Consumer Protection Act (CCPA) took effect on January 1, 2020. Similar to GDPR, CCPA is intended to protect person information and also articulates the rights that California consumers have regarding their information. CCPA applies specifically to residents of California.

The definition of Person Information in CCPA is very similar to GDPR's definition of Personal Data: "Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household."

Just as GDPR establishes rights for EU citizens, CCPA establishes certain rights for California residents:

• The rights to disclosure of data collected and sold: California residents have the right to request access to their personal information and to ask how their data is used by the company after it has been gathered. If the information is being shared or sold, this must be disclosed when requested.

• The right to deletion: Companies must delete a Consumer's personal information upon request.

• The right to opt out of sales of Personal Information: If a company sells personal information, consumers have the right to opt out.

• The right to non-discrimination: If a consumer exercises their rights under CCPA, the business may not discriminate against the consumer. For instance, they company cannot deny service or charge different rates to a consumer who exercises their rights under CCPA.

Contact Us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at: inquire@phaidra.ai. You can also submit a Personal Data Request form below.