GENERAL PRIVACY POLICY

Last updated January 27, 2021

Fenix Group International, LLC (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites, https://www.fenix.group/, https://www.fenixpharma.com/go, https://dashboard.fenix.group/ and https://celltelligence.com/ including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”).. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

 

COLLECTION OF YOUR INFORMATION

 

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site, such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data
Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, Stripe, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

 

USE OF YOUR INFORMATION

 

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Increase the efficiency and operation of the Site.
• Monitor and analyze usage and trends to improve your experience with the Site.
• Notify you of updates to the Site.
• Offer new products, services, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Request feedback and contact you about your use of the Site.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Site.

 

DISCLOSURE OF YOUR INFORMATION

 

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy 
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

 

TRACKING TECHNOLOGIES

 

Website Analytics 
We may also partner with selected third-party vendors, such as Google Analytics, Heap Analytics, Keen, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or Network Advertising Initiative Opt-OutTool or DigitalAdvertisingAllianceOpt-OutTool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

 

THIRD-PARTY WEBSITES

 

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

 

SECURITY OF YOUR INFORMATION

 

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

 

POLICY FOR CHILDREN

 

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

 

CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  If you set the DNT signal on your browser, we will respond to such DNT browser signals.

 

OPTIONS REGARDING YOUR INFORMATION

 

Account Information
You may at any time review or change the information in your account or terminate your account by:

• Contacting us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Contacting us using the contact information provided.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

 

CALIFORNIA PRIVACY RIGHTS

 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

CONTACT US

 

If you have questions or comments about this Privacy Policy, please contact us at:

Fenix Group International, LLC
201 Washington Street
Suite 328
Reading, PA 19601 USA
dataprivacy@fenix.group

CONTACT PRIVACY POLICY

Last updated January 27, 2021

If your using the website’s contact form and you’re a European Union citizen and resident, the following information may be of interest to you:

1. WHO IS THE DATA CONTROLLER?

Your information shall be processed by the following Data Controllers acting as Joint Data Controllers in compliance with Article 26 of the GDPR

FENIX GROUP INTERNATIONAL, LLC

47-2188503, 201 Washington Street, Suite 328, Reading, PA 19601 USA

dataprivacy@fenix.group
FGI Life Sciences, S.L.

B67144956, Calle Paris, 207, Planta 3, Puerta 2, Barcelona (08008)

dataprivacy@fenix.group

2. WHAT ARE THE MAIN PURPOSES FOR PROCESSING YOUR DATA?

When you send us data through the contact form, we will use your personal data to (1) analyze and manage your requests, questions and consultations by contacting you with the purpose of giving you an answer or sending you any information requested by you; and (2) if you’ve given us your consent, to send you promotional communications on news, events and activities related to our services and products. These communications will be made by any automated means or not (email, SMS, MMS, Internet, telephone, instant messaging services, etc. …).

3. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

Our legal basis for processing your data is your consent: when you’re sending us data through the form, you’re giving us your consent for processing your personal data within the framework of the question, consultation and/or request; and when you check the box agreeing to receive promotional communications you’re giving us your consent to send you those communications.

4. HOW LONG DO WE STORE YOUR DATA?

We shall process your personal data for the period necessary to comply with the purposes set out in this Privacy Policy, as well as to keep your personal information in compliance with the provision of the applicable law and regulations, especially in relation to the legal statute of limitations, and for the exercise or defense of claims.

If you’ve given your consent to send you promotional communications, we will process your personal data until you withdraw your consent.

Please note that, in some cases, we may retain your data for the time necessary to exercise or defend claims, requirements, liabilities and legal and/or contractual obligations arising from the processing, always being dully blocked.

5. WHAT ABOUT MINORS?

The website is aimed at adults who are interested in our services as part of their business activity. Therefore, it is not expected that minors contact or contract with us through the website. We do not knowingly collect information from minors. If parents or legal guardians believe that they children have submitted us personal data, please contact us by sending us an e-mail to dataprivacy@fenix.group

6. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

Our legal basis for processing your data is your consent: when you’re sending us data through the form, you’re giving us your consent for processing your personal data within the framework of the question, consultation and/or request; and when you check the box agreeing to receive promotional communications you’re giving us your consent to send you those communications.

7. WHO COULD BE THE RECIPIENTS OF YOUR DATA?

Your personal data will not be disclosed to third parties without your express consent. However, depending on the purposes for which the personal information is collected, such information may be accessed, without distinction, by the following persons:

• Employees and/or collaborators authorized by the Data Controller/s, always subject to the applicable data protection regulations;
• Any other entity or service provider, or other third party who has been permitted access to your personal data is required to enter into a Data Processing Agreement, in compliance with Article 28 of the GDPR.
Whenever your data is transferred from a country in the European Economic Area (EEA) to a country outside the EEA, we ensure that we or our suppliers have an adequate personal data protection level. To this end, we use and/or contract data processors who will process your personal data using recognized data protection safeguards. For example, under the EU-U.S. Privacy Shield Framework, or where applicable, under standard contractual clauses approved by the European Commission for the transfer of personal data.
• Intra-group transfers. On the basis of the proper functioning of the corporate group and based on the legitimate interest pursued by all the entities of FENIX GROUP, it is necessary to transmit personal data within the corporate group for internal administrative purposes, which may include your personal data. Because the Parent company, FENIX GROUP INTERNATIONAL, LLC is located in the United States, a third country that doesn’t provide an adequate level of protection, all transfers of personal data to the United States and/or from the United States to the European Economic Area, will have as a legal ground the European Commissions’ Standard Contractual Clauses. In particular, Decision 2001/497/EC, of 15th June 2001, and Decision 2004/915/EC, of 27th December 2004, providing contractual clauses for the transfer of personal data to third countries between Data Controllers.

8. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

If we process your personal data, you’ve the following rights:
• Right to request access to personal data: you may ask the Data Controller/s if it is processing your data, and if it is, you may have access to the same.
• Right to request the rectification of your data in case they are inaccurate or to request data to be completed if they are incomplete.
• Right to request the erasure of your data.
• Right to request the restriction of processing: in this case, we will only keep data for exercising or defending against claims.
• Right to object to processing: the Data Controller/s will cease to process personal data, unless they must continue to be processed for legitimate reasons or for exercising or defending against possible claims.
• Right to the portability of data: in the event that a user would like for their data to be processed by another data controller, the Data Controller/s will facilitate the transfer of their data to the new controller.
• Right to not be the object of automated decision-making regarding your personal data.
If you had given your consent for any specific purpose, you may withdraw that consent whenever you wish, without affecting the lawfulness of the processing based on the consent prior to withdrawal.

To exercise your rights, please send us an e-mail to dataprivacy@fenix.group

If you haven’t obtained satisfaction in the exercise of your rights, you may lodge a complaint with a supervisory authority. If you’re a data subject located in Spain, you may file a complaint with the Spanish Data Protection Agency https://www.aepd.es

9. UDPATES

We will only use your personal data as set out in this Privacy Policy which is in force at the time, we collect your information. If any revision or update is done that affects the processing of your personal data, we will inform you.

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