Title: Phello Privacy Policy


Privacy Policy

Last modified: September 18, 2023


At Phello, LLC ("Company" or "We") we are committed to your success and will protect your privacy through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website hellophello.com (our "Website") as a guest to our Website (a “Visitor”) or a subscriber (a “Subscriber”) to our services (“Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  This policy applies to information we collect on this Website, in email and other electronic messages between you and this Website and offline through customer service telephone communications with us.

We take your privacy seriously and we will only disclose your personal information to third parties under the following circumstances:

· With your consent;

· To provide our Services to you (including all of the features of our services such as the personal website, PRM Tool, and email platform as further  
  explained below). 

·To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal
 information confidential and use it only for the purposes for which we disclose it to them.

· To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

· To enforce or apply our Terms of Service and other agreements, including for billing and collection

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Phello, LLC, our clients, or others.

·To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of
 Phello, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by
 Phello, LLC about our Website users is among the assets transferred.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or subscribe to any plan for our Services. By accessing or using this Website or subscribing to our Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Minimum Age

You must be at least 18 years of age to use our Website. Please visit our Terms of Service for additional information regarding the use of our Services.

Information We Collect About You and How We Collect It

We collect several types of information from our subscribers and guests to our Website:

·         Your Account and Initial Consultation.  When you subscribe to our Services, we will ask you for information to set up your subscription and determine your goals and objectives.  This includes information by which you may be personally identified, such as name, postal address, e-mail address, telephone number and user id and any other identifier by which you may be contacted online or offline as well as a password (“personal information”).  You may be asked to provide your payment information online and asked to review and sign our Terms of Service.

·         Your Personal Web Page. Once we have set up your subscription, we will also collect such information as you choose to provide for your personal webpage such as information related to your education, professional history (such as job title and company), professional goals, career accomplishments, insights, honors, awards, and skills, or any other information you chose to incorporate into your profile.   You also may choose to provide additional information to be published or displayed (hereinafter, "posted") on your personal webpage, or transmitted to other users of the Website or third parties through the email platform. (We refer to all content you supply to us in any manner or post on the Website (including on your personal webpage) as "User Contributions").

·         Your Professional Relationship Manager.  If you are a subscriber to an applicable plan, we also allow you to input information to populate our professional relationship manager tool (the “PRM Tool”), such as names, addresses and phone numbers of your contacts and any other relevant information that you select to enter or import into the PRM Tool.

·         Your Email.  If you are a subscriber to an applicable plan, and you choose to use our email system, we will collect and retain your usage data from our third party email provider. We may have access to your email and contact list for client service purposes.

·         Client Service.  If you are a subscriber and use our services to develop a professional marketing plan and individualized personal marketing communications, we may collect specific information from you to assist you in achieving your goals.  When you call us for client service, we may have access to your personal webpage, PRM Tool contacts, personal customized marketing plans and correspondence, and email platform to be able to respond to your client service needs.  We may keep records of calls to us and copies of your correspondence via email.  We may email you surveys and we may retain your responses for research purposes and to enhance our services for you.

·         Your Account Subscription and Maintenance.  If you are a subscriber, we will collect details of transactions you carry out through our Website for the subscription to our Services. You may be required to provide financial information before subscribing or renewing your subscription through our Website.

·         Your Usage Details.  If you are a Subscriber or a Visitor, we may collect information about your internet connection, the equipment you use to access our Website and usage details automatically as you navigate through the site or use our Services. Information collected automatically may include usage details such as information about your browsing actions and patterns and, information about your computer and internet connection including your IP address, operating system and browser type and information collected through cookies, web beacons, and other tracking technologies.   A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Pixel Tags (Web Beacons) may be used in the future to monitor access to various types of content that is created on but may or may not be hosted on our Website.  Content that is hosted on and served up by our Website may be monitored and tracked by API and Page Load monitoring. Where content is created on our Website but is rendered by other third party service providers not running on our site, tags may be embedded in the content to allow us to track/monitor access to that content. For example, we may embed tags in email in the future to monitor actions like Opens and Clicks.

Use and Sharing of Your Information

We recognize that any User Contributions you provide to us may contain your personal information and we will only use and share them as explained below.  We will also use your personal information to (i) to provide you with notices about your subscription, including expiration and renewal notices and (ii) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection and to notify you about changes to our Website, Services or tools or any other products or services we offer or provide.

·         Your Personal Webpage.  Your personal webpage establishes your professional brand and is intended to be viewed by third parties, whether they are other Subscribers, Visitors, or third parties that discover your page through targeted searches or by your express invitation.  Any User Contributions you choose to submit for posting or directly post on your personal webpage will be considered non-confidential and non-proprietary and may be viewed by Visitors, any invitees you send it to, or fellow Subscribers.  Please be aware that in addition to expressly stated information you post, any information you choose to post (or instruct us to post) may contain sensitive personal information that may be conveyed by the context of your submission or photographs (for example, a photo may reveal your age, gender or marital status, your name may reveal gender, your education information may reveal age).   We ask that you are mindful of your submissions and the context in which you present this information.  You expressly agree and acknowledge that your User Contributions are posted on the Website and transmitted to others at your own risk and that you have no expectation of privacy or confidentiality in these User Contributions. You are in charge of what is posted on your personal webpage.  We will never post your personal information on the website without your prior consent.   You control how your personal website will be indexed for search engines, for example, whether you will be “publicly searchable” on the public internet when someone enters a search for your name. Even, if you have not elected to be “publicly searchable,” however we cannot guarantee your privacy.  We cannot control the actions of third parties, including others with whom you may choose to share your personal website or other User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.  In addition, if you choose to change your settings, or delete your personal webpage, we cannot guarantee that the prior webpage will not be viewable.  Third party search engines may not update their databases in a timely manner and we cannot control the practices of these third parties.  As a result outdated information (including any information on your personal webpage prior to the change in settings) may continue to be indexed by these search engines.  Please see “Accessing and Correcting Your Information” below.

·         Your Emails. You are responsible for controlling any User Contributions you chose to share via our automated email system.   You understand that we use a third party service provider to provide our email system.  This third party may have access to your communications and contacts for customer service purposes.  Our service providers are contractually bound to maintain the confidentiality of your communications and contacts and to use them only to provide the Services.  Email transmission may not be encrypted, and security of information transmitted through the internet can never be guaranteed.  We encourage you not to communicate confidential information through email. In addition, we caution you that any email you send may be forwarded and/or read by parties other than the intended recipient.  We cannot guaranty the privacy of your emails as we cannot control the actions of third parties.

·         Your PRM Tool.  Depending on your selected plan, we may have access to your PRM Tool to provide our Services to you.  We will never use or sell your contact lists (whether through the email platform or the PRM Tool) for advertising or marketing purposes.

·         Your Usage Details. We and our third party service providers may collect, synthesize and analyze non-personally identifiable data (information that does not identify an entity or a person) that results from your use of the Website, email system or other Services. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to enhance our services, customize our website, speed up searches and recognize you when your return to our Website.  We use analytical tools to monitor the Website’s usage to understand what features are used most heavily and where time is being spent.  This data provides insights to us on where future development, tools and performance improvements may be of the greatest value to our Subscribers.  We (and our third party service providers) may also collect usage data from our third party email platform provider.   This information may be used to determine the frequencies, bounce rates and recipients of emails sent through the Phello® email server.   This data may be used to enhance and further develop our Services or those of our third party service providers and for any other lawful purpose.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Accessing and Correcting Your Information

You can review and change your personal information on regarding your account and on your personal webpage by logging into the Website and visiting your account platform.

You may also contact us though the Website to correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, including your individual web page, if applicable, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service .

Archiving and Return of Your Personal Information

If your subscription is cancelled or terminated, you will no longer be able to access and use the Services including your personal webpage and PRM Tool (if your plan allows, you may continue to use any customized deliverables such as customized marketing plans or letters that have been fully paid for and downloaded or otherwise have been delivered to you prior to termination or cancellation of your subscription). Your access to your hellophello.com webpage will be disabled.  We are under no obligation to store User Contributions.  After termination or cancellation of your subscription, no User Contributions will be provided to you. Further your User Contributions and contacts may, but are not required to be, deleted.  You agree that we have no liability to you (or any third party) as a result of limiting or terminating your access to hellophello.com, the User Contributions or your contacts on the email platform or the PRM tool.  We may, in our discretion, retain the personal information you provided if we need to do so to comply with legal or regulatory obligations, enforce any agreements or resolve disputes.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the Website or write us at: 349 West Commercial Street, Suite 3030, E. Rochester, NY 14445.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  All information you provide to us is stored on our secure servers behind firewalls.   If you enter payment information on our site in connection with a subscription to our Services, this information is sent directly from your browser to a third party service provider that we use to manage payments.  We do not store your credit card information on our servers.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about information you select to share in public areas of the Website like your personal webpage both expressly and what can be inferred from your content and photograph selections.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

Please review this page often as we may make changes to our privacy policy from time to time. Any changes to the privacy policy will be effective as of the published effective date.  If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account  or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us through the Website at www.hellophello.com or write us at: 349 West Commercial Street, Suite 3030, E. Rochester, NY 14445.