This Privacy Policy is intended to inform you of our policies and practices regarding our use and disclosure of the information that you submit to us, and the information that we collect from you through our website and our mobile application.

Whenever we use the words “we” or “us” or “Phare,” we are referring to Creative Tech Solutions LLC (doing business as Phare.com), and to the affiliates, subsidiaries and parent companies of Creative Tech Solutions, LLC. Whenever we use the words “our website,” we are referring to https://www.phare.com and to our mobile application(s) (“app”).

Whenever we use the word “You” or “you” we are referring to the visitors to, and users of, our website (including our app), and to Subscribers (those who have registered to use our website or app).

This Privacy Policy is divided into the following sections:

  1. Definitions
  2. Consent
  3. How We Collect Personal Information
  4. How We Use Personal Information
  5. Our Disclosure of Your Personal Information
  6. Advertising
  7. Social Network Widgets; External Ad Blocking
  8. Mobile Applications
  9. Information From Children Under 13
  10. Links to Other Websites; Operating Systems
  11. Security
  12. Questions about this Privacy Policy
  13. How to Access or Correct Personal Information or Opt Out of Marketing and Advertising
  14. Revisions to the Privacy Policy

1. Definitions

“De-identified Information” means information that is no longer associated with you, or linked to your Personal Information (as defined below). De-identified Information does not reference the identities of individual persons.

“Cookies” are small pieces of information that a website, including our website, sends to your computer or to your mobile device while you are viewing a website or an app. We use both session Cookies (which expire after you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personalized and interactive experience on our website. Persistent Cookies can be removed by following your Internet browser help file directions. If you choose to disable Cookies, some areas of our website may not work properly.

An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer, tablet or other device when you use the Internet / world wide web. In some cases, your IP Address stays the same from browser session to browser session; if you use a consumer internet service provider, your IP Address may vary from session to session. We track IP Addresses in conjunction with session Cookies to analyze our web page traffic flow and to identify location of the computer.

“Personal Information” is information about you that is linked to you as an individual, such as your name, postal address, email address, social media identifier (e.g., @janedoe; upseller_johndoe), phone number, full credit card number and expiration date, and account username and log-in password to our website. Personal Information does not include technical information such as unique device identifiers, randomly assigned unique identifiers in cookies, mobile device name or identifier, or IP addresses, unless that technical information is linked to you personally as an identifiable individual by associating the technical information with other Personal Information.

As detailed below, we and our business partners obtain and keep Personal Information when you become a Subscriber, send us an email, interact with our website, or otherwise communicate with us.

2. Consent

Our website is maintained in the state of Ohio in the United States, and by submitting your Personal Information to us, either through our website or app, or by other means, you are agreeing to the collection and storage of your Personal Information in the United States.

When you submit Personal Information and De-identified Information to us, either through our website or through our app, or by other avenues, it means that you have agreed to this Privacy Policy, and that you expressly consent to the use of your Personal Information in the United States, according to this Privacy Policy.

Please note that your Personal Information will be used by Phare in the country where it was collected, as well as in the United States, where laws regarding the use of Personal Information may be less strict than the laws in your country.

3. How We Collect Personal Information

The Personal Information that we gather from you helps us learn about our Subscribers and our potential customers. We use this Personal Information to better tailor the features, performance and support of our services and to offer you additional information.

We (and our business partners, on our behalf) collect and keep Personal Information that you submit to us voluntarily to our website, through our mobile app, through any other means, such as social media (e.g. Facebook, Instagram) or other social or sharing platforms or technology, now known or hereafter developed, and to our customer service center; and through third party websites or emails, in the following ways:

  • When you register and set up an account on our website, we collect your name, postal address(es), telephone number(s), your account username, password, email address.
  • When you contact us by email, we collect your name, email address, and any other information contained in the email that you send us.
  • When you sign up to receive text messages, we collect your mobile telephone number.
  • When we receive Personal Information about you from other sources, we will add this information to the information we have already collected from you.
  • When you call, email or chat with our customer service, we may collect all or some of the following: name, email address, postal address, telephone number(s), and other information that you provide during the interaction.

On our website, we (and our business partners, on our behalf) collect other information from you automatically, through the use of technology, without you taking steps to submit that information, whenever you use our website for any purpose in the following ways:

  • As you navigate our website, we collect information including your IP address, browser type, domain names, access times, operating system, and other device identification information.
  • We also use Cookies (described in Section 1), pixels, and navigational data like uniform resource locators (URL) to collect information regarding the date and time of your visit, the products for which you searched and viewed, and the other resources on our website that you used or visited. In addition, our website and emails from Phare may contain code or pixels that cause Cookies to be placed in, or read or modified from, a user’s or email recipient’s browser cache.
  • When you access our website from mobile devices (such as smart phones or tablets), we collect information including access times, the operating system, the pages you searched and viewed, and the other resources on our website that you used or visited.
  • We may use and associate historical data with a computer or device as part of our efforts to prevent fraud, credit card fraud, or other illegal activity.

4. How We Use Personal Information

We use your Personal Information to respond to requests that you make, to help us serve you better, to provide advertisements and marketing to you, and to provide you with a personalized website experience. If you have signed up to receive email from us or for text messages, we also use your Personal Information to provide you with promotional emails and text messages for our services and products, and for other marketing and advertising purposes.

See Section 6 for more information.

Personal Information that we collect from a particular browser or device, including a mobile device, may be used with another computer or device that we have linked to the original browser or device, including a mobile device, on which such Personal Information was collected.

We limit our employees’ access to Personal Information to those employees with a business reason for knowing such information, and those employees will use the information only for business reasons.

We may create De-identified Information from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may use this De-identified Information to analyze request patterns and usage patterns so that we may improve our services and products. Because this De-identified Information does not identify you, we use and disclose De-identified Information to third parties at our discretion.

If you provide feedback to us, we may use your feedback for any purpose. We will collect any information contained in your communication and will treat the Personal Information in the communication in accordance with this Privacy Policy.

Personal Information and other information and user-generated content that is submitted to our website, to Phare through our mobile apps, or to Phare through any other means, such as social media (e.g. Facebook, Instagram) or other social or sharing platforms or technology, now known or hereafter developed, may be used by Phare in advertising or other marketing or promotional activities, without compensation to you.

5. Our Disclosure of Your Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, rent, or share your Personal Information with third parties. We share your Personal Information with third party service providers in the United States that provide advertising and marketing services for us, including distribution of postal mail, electronic alerts, email, electronic (digital) advertisements, and mobile text messages to our Subscribers and potential Subscribers. These third party service providers are required not to use your Personal Information, except to provide the services requested by us, and they are bound by confidentiality agreements for their use of your Personal Information. You expressly consent to the sharing of your Personal Information with our third party service providers in the United States and elsewhere.

We reserve the right to share some or all of your Personal Information with our parent company (and with its subsidiaries, joint ventures, and parent company) and with our subsidiaries, joint ventures and other companies under the common control of Phare or under the common control of our parent(s) (collectively, “Affiliates”), for the purposes described in this policy. We will require the Affiliates to honor this Privacy Policy.

Regardless of any choices you make regarding your Personal Information, we may disclose your Personal Information if we believe in good faith that disclosure is necessary to (a) comply with laws or to respond to subpoenas or other judicial orders served on us, or (b) to protect and defend the rights or property of Phare or third parties.

To provide offers that are of interest to you, we may allow other companies to place advertisements and other technology on our website. As a result of your visit to our website, advertisement server companies may collect information such as your domain type, your IP address, and clickstream information. See Section 6 for more information.

We may also use and disclose Personal Information for fraud detection and prevention. Personal Information and device identification information may be combined with information from other sources and used by us, or by a third party retained by us, to help detect and prevent fraud or other illegal or illegitimate activity. All or part of your Personal Information or device identification information may be kept by us or kept by the third parties involved in fraud detection, and used in future fraud prevention efforts. Information that is believed to be fraudulent may be shared with other retailers, banks, and law enforcement to help prevent illegal activity.

We may use and disclose Personal Information in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction. If the sale occurs, the purchaser will be entitled to use and disclose the Personal Information collected by us, and the purchaser will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

6. Advertising

We use “interest-based” advertisements, also known as “online behavioral advertising.” Online behavioral advertising is advertising that is directed to you based, at least in part, on your Internet browsing behavior. We share Personal Information with the third parties that conduct advertising campaigns for us. Third parties and their affiliates collect certain information as a result of their “tags” and other automated technology being on our website. The information that they collect includes the name (URL) of the web pages you view while on our site, your IP address, time of visit, information about your browser software, information about your device, and randomly-assigned identifiers stored in Cookies, which they use to target and serve advertising to you. We will use all this information to serve advertising to you.

In connection with online behavioral advertising, some third parties involved in advertising may maintain their own proprietary consumer databases that allow them to personally identify or track website visitors. Other third parties have proprietary technologies to determine what additional devices you may use, and they may then display advertisements on those additional devices.

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third parties as defined by the initiative. For more information, visit https://www.w3.org/.  As explained below, some websites, including our website, will ignore a “do-not-track” signal.

As required by Section 22575 of the California Business and Professions Code, the following disclosure is made to California residents and to residents of other states: Our website does not alter its behavior or change its services when it receives a “do-not-track” flag or signal from your browser. As described in Section 3, we use Cookies and other tools to collect information about you when you visit our website to better tailor the features, performance and support of our products, services, stores, and website. After you leave our website, we do not track your online activity on other websites, but third parties (and their affiliates) may track your online activity to offer you advertisements.

You can make decisions about your privacy and the ads you receive. To some extent you can control whether companies serve you on-line behavioral advertising by visiting the Digital Advertising Alliance website and using its opt-out: https://www.aboutads.info/choices/. The DAA opt-out requires that cookies not be blocked in your browser. You may also visit the website of the Network Advertising Initiative and use its opt-out: https://www.networkadvertising.org/. Different companies may belong to one or more advertising organizations, and opting out from one or more groups may not stop all interest-based advertisements. As explained in Section 11, we do not represent or warrant that the actions taken on other websites will be effective or that all advertisements will be blocked.

For mobile devices and applications, you can visit the following website to opt-out of behavioral advertising: https://www.aboutads.info/appchoices. As explained in Section 11, we do not represent or warrant that the actions taken on other websites will be effective or that all advertisements will be blocked. See also Section 8 for more information on mobile applications, geo-location tracking, and opt-outs.

Opt-outs are unique to each mobile device or web browser. An opt-out completed on a specific web browser will not transfer to other browsers or to your mobile device. An opt-out completed on your mobile device will not transfer to a different mobile device or to web browsers.

As an alternative to the DAA opt-out, you can also elect to block all Cookies from first parties (such as those from our website) and Cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software. We do not represent or warrant that these actions will be effective to accomplish their purpose.

7. Social Network Widgets; External Ad Blocking

Our website may include social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the plug-in or widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn what information they collect, use, and share.

Our website includes an external advertisement blocking service that attempts to block advertisements and other “pop-ups” that are not authorized by us when visitors come to our website. We apologize for any inconvenience this may cause you while visiting our website. We make no representation or warranty that the service will stop any or all unauthorized advertisements or pop-ups while visiting our website.

8. Mobile Applications

We collect information you provide through the mobile app when you log in, such as your email address. We also collect information regarding the type of mobile device, operating system version, IP address, geo-location, device name, and unique device identifiers. See also Section 3 for additional information that we collect. If you do not want your geo-location information to be collected, you can go to “settings” or similar function of your mobile device and disable the location feature. In addition, you can visit the following website and opt-out of some geo-location tracking by the participating companies: https://optout.smart-places.org/.

9. Information from Children Under 13

We do not intentionally gather Personal Information about visitors to our website who are under the age of 13.

10. Links to Other Websites; Operating Systems

Our website may provide link(s) to another website or Internet location. We provide these links merely for your convenience, and we do not endorse the other website or location, its contents, or any goods or services available through that website. We have no control over, do not review, and are not responsible for these other websites, their content, or any goods or services available through the websites. Our Privacy Policy does not apply to these other websites. The privacy policies of the operators of the websites will be applicable when you access their websites through the links provided on our website.

The operating system (e.g., Android, iOS) that your device operates on will have its own privacy policy that governs your use of that operating system and device.

11. Security

Our website has implemented electronic means of protecting Personal Information. Even though we have taken steps to ensure that Personal Information is not accessed, used, or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with Personal Information.

12. Questions About this Privacy Policy

If you have questions regarding this Privacy Policy, please contact us at support@phare.com.

13. How to Access or Correct Personal Information

To change your information, please visit the “My Account” section of our website.

14. Revisions to the Privacy Policy

This Privacy Policy is subject to revision and changes. If you object to any changes, you must stop doing business with us, including business on our website. Your continued use of our website will indicate your acknowledgment of the changes and agreement to be bound by the terms and conditions of the Privacy Policy, as revised.

This policy was issued in June 2022.