Privacy Policy

Phantom Data LLC (“Phantom Data,” “we,” “us,” or “our”) respects privacy and is committed to handling personal information responsibly. This Privacy Policy describes how we collect, process, use, retain, disclose, sell, share, and otherwise handle personal information in connection with our website, platform, data products, support services, marketing, and other services that link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy applies to personal information we collect or process:

• Through the Services and our website;
• In communications with us, including email, text, telephone, chat, and other electronic communications;
• When you create or use an account, request a trial, purchase Data, contact support, receive marketing, or otherwise interact with the Services;
• Through cookies, pixels, web beacons, log files, device identifiers, and similar technologies used in connection with the Services; and
• When we license or sell Property Data to Users.

This Privacy Policy does not apply to information collected by a third party through a website, application, product, or service that does not link to this Privacy Policy. We may provide additional notices for a particular feature, activity, product, or jurisdiction.

1. Who We Are and Our Data-Broker Role

Phantom Data operates a business-to-business platform that licenses or sells property-owner and contact data to Users. We obtain brokered personal information from one or more third-party data providers. We do not independently collect, create, enrich, score, verify, or otherwise modify the Property Data records we make available through the Services.

Phantom Data may be considered a data broker under applicable law because it licenses or sells personal information about individuals with whom it does not have a direct relationship. This Privacy Policy describes our practices concerning individuals whose information may be included in Property Data, as well as website visitors, Users, prospective Users, and other persons who interact directly with us.

Important distinction. Phantom Data processes different categories of information for different purposes. We process account, payment, communications, device, location, and usage information from people who interact directly with our Services. Separately, we make Property Data available to Users. The rights, choices, request-verification methods, retention periods, and disclosures applicable to a category of information may differ based on the type of information and the reason we process it.

2. Children’s and Minors’ Information

Our Services are intended for Users and are not directed to children. We do not knowingly collect personal information from children under thirteen (13) years of age, and we do not knowingly maintain Property Data about known minors. If you believe we have collected personal information from a child in error, please contact us at [email protected].

3. Personal Information We Collect or Process

The personal information we collect or process depends on how you interact with us and the Services.

A. Account, Contact, and Business Information

We may collect your name, business name, email address, telephone number, username, password, business address, billing address, and other contact or account information you provide when creating an account, requesting a trial, placing an order, subscribing, adding funds, contacting support, or otherwise communicating with us.

B. Payment and Transaction Information

We may collect or receive billing address, payment-method information, payment status, deposits, purchases, subscription status, order history, credits, refunds, chargeback-related information, and related transaction records. Payment-card information is processed by payment processors. We do not intentionally store full payment-card numbers.

C. Communications and Support Information

We may collect messages, requests, feedback, attachments, call or meeting information, and other information you provide when communicating with us. To the extent permitted by applicable law, we may monitor or record communications for training, quality assurance, security, dispute resolution, service improvement, and business-administration purposes.

D. Device, Usage, Location, and Technical Information

When you visit or use the Services, we and our service providers may automatically collect IP address, browser type, operating system, device identifiers, device settings, language, Internet-service-provider information, general geographic location derived from an IP address, and information about your device’s location when you permit or enable location access through your device or browser.

We may use location information to provide location-related functionality; understand general geographic distribution of usage; prevent fraud and abuse; maintain security; analyze and improve the Services; and comply with applicable law. We do not require location access for ordinary use of the Services. If you disable location access through your browser or device settings, some location-related functionality may be unavailable or less accurate.

We may also collect usage and log information, including pages viewed, features used, search or query text, Orders, selections, clicks, timestamps, referring pages, session information, error reports, and interactions with our communications. We use cookies, pixels, web beacons, SDKs, local storage, log files, and similar technologies to operate, secure, analyze, improve, market, and measure the Services.

E. Property Data

“Property Data” means the property-owner and contact information made available through the Services. Property Data may include owner and co-owner names, mobile telephone numbers, email addresses, property addresses, and mailing addresses. A property or mailing address may include its associated street address, city, state, and ZIP code. We may make additional categories of Property Data available from time to time through the Services, an Order, or a written agreement with a User.

Search, filter, or selection criteria available through the Services are not necessarily included in a delivered file. We do not independently collect, create, enrich, score, verify, or otherwise modify Property Data records before making them available to Users.

F. Property Data Accuracy and Correction

Property Data may be incomplete, delayed, outdated, unavailable, or inaccurate. Phantom Data does not guarantee the accuracy, completeness, currentness, ownership association, property association, deliverability, or legal usability of any owner name, telephone number, email address, property address, mailing address, or other Property Data element.

If you believe that Property Data concerning you is inaccurate, incomplete, or should not be licensed or sold, you may submit a correction, deletion, suppression, restriction, or opt-out request using the procedures in Section 9. We will review and process the request in accordance with applicable law and may correct, restrict, delete, suppress, or otherwise address the record where appropriate.

G. Aggregated and Deidentified Information

We may create and use aggregated, anonymized, or deidentified information for any lawful purpose, including to operate, secure, analyze, improve, and market the Services. We will maintain and use deidentified information in deidentified form and will not attempt to reidentify it except as permitted by applicable law.

H. Information We Do Not Intend to Collect Through the Services

We do not intentionally collect or process biometric information, government-issued identifiers, health information, non-public education information, racial or ethnic origin, religious or philosophical beliefs, union membership, sex life or sexual-orientation information, or the contents of private communications not directed to us. We also do not intentionally collect or maintain Property Data about known minors. If we learn that information has been provided to us in a manner inconsistent with this Privacy Policy or applicable law, we will take appropriate action.

4. How We Collect Personal Information

A. Information You Provide Directly to Us

We collect personal information that you provide when you interact with the Services. For example, we collect information when you:

• Create, update, maintain, secure, or close an account;
• Request, activate, or use a trial;
• Place an Order, add funds, purchase Data, enroll in a plan or subscription, select or decline a Scrub Feature, or otherwise complete a transaction;
• Provide payment, billing, or contact information;
• Communicate with us through email, text, telephone, chat, support channels, social-media channels, or other communications;
• Respond to a survey, promotion, contest, event, marketing campaign, or request for feedback;
• Submit an inquiry, support ticket, complaint, privacy request, opt-out request, correction request, deletion request, or appeal; or
• Otherwise provide information to us through the Services or in connection with a business relationship.

The information you provide may include your name, business name, email address, telephone number, username, password, account credentials, billing address, payment-related information, business address, order details, messages, attachments, and any other information you choose to provide.

B. Information Collected Automatically Through the Services

As you navigate through and interact with the Services, we and our service providers may use automatic data-collection technologies to collect information about your device, your use of the Services, and your interaction with our communications. The information collected automatically may include usage details, IP address, browser type, operating system, device identifiers, device settings, language, Internet-service-provider information, general geographic location derived from IP address, and information about your device’s location when you permit or enable location access through your device or browser.

We may collect information concerning pages viewed, features used, search or query text, Orders, checkout selections, Scrub Feature elections or non-elections, clicks, timestamps, referring pages, session information, error reports, and interactions with our communications. We may also collect information concerning your access to the Services, the date and time of your interaction, the pages or features you use, the files or content you access, and technical information generated by the browser or device you use.

The technologies we use may include:

• Cookies. Cookies are small files placed on your device when you interact with the Services. You may refuse or disable certain cookies through your browser or device settings. If you do so, some parts of the Services may not function properly.
• Web beacons, pixels, and similar technologies. Our website, communications, and advertising may contain small electronic files or similar technologies that allow us and our service providers to measure visits, engagement, email opens, campaign performance, advertising effectiveness, and related statistics.
• Log files and diagnostic information. Our servers and service providers may automatically collect service-related, diagnostic, usage, performance, and security information, including IP address, device information, browser type and settings, system activity, error reports, and timestamps.
• Device and location settings. Depending on your device and settings, we may receive device information and general or device-based location information. We use that information as described in this Privacy Policy. We do not use session-replay tools.

C. Information From Service Providers, Affiliates, and Business Partners

We may receive personal information from service providers, affiliates, business partners, and other parties that support our business or help us provide, secure, market, measure, or improve the Services. These sources may include payment processors, hosting and cloud-infrastructure providers, communications providers, customer-support providers, fraud-prevention and security providers, analytics providers, advertising partners, identity and account-verification providers, and professional advisors.

Information received from these sources may include payment status, transaction confirmations, account-related information, security and fraud signals, device and usage information, advertising and campaign information, and information needed to provide, secure, support, or market the Services.

D. Property Data From Third-Party Data Providers

We obtain the Property Data made available through the Services from one or more third-party data providers. We do not independently collect Property Data directly from the individuals whose information may be included in it.

We also do not independently create, enrich, score, verify, or otherwise modify Property Data records before making them available through the Services. Property Data may include the categories described in Section 3.E. Search, filter, or selection criteria available through the Services are not necessarily included in a delivered file.

5. How We Use Personal Information

We use personal information for the following business and commercial purposes:

A. Providing and Administering the Services

We use personal information to provide, operate, maintain, troubleshoot, secure, and improve the Services. This includes creating and administering accounts; authenticating Users; providing access to the Platform; processing Orders; delivering Data; administering trials, plans, subscriptions, credits, and other Service features; and providing customer support.

We use account, contact, transaction, and technical information to verify access, maintain account security, provide requested functionality, identify and resolve service issues, enforce usage limits, and communicate with Users about the Services.

B. Processing Orders, Payments, and Transactions

We use personal information to process deposits, purchases, subscriptions, charges, refunds, credits, payment disputes, and other transactions. We also use it to maintain transaction records, address billing issues, prevent payment fraud or abuse, enforce our payment terms, and carry out our obligations under applicable agreements.

C. Licensing Property Data to Users

We use Property Data to make Property Data available to Users through the Services. We may process Property Data as necessary to respond to a User’s Order, apply order selections, produce an export or other output, maintain order records, administer permitted suppression functionality, and meet legal, privacy, security, or data-source obligations.

We do not independently collect, create, enrich, score, verify, or otherwise modify Property Data records before making them available to Users.

D. Communicating With You

We use personal information to communicate with you about your account, trial, Order, transaction, payment, support request, security matter, policy change, Service update, legal notice, or other non-marketing matter. We may also use personal information to request feedback, respond to questions, administer promotions, and provide information you request.

E. Marketing, Advertising, and Business Development

We may use personal information to market and advertise the Services; send promotional communications; measure and improve marketing campaigns; build, maintain, or use advertising audiences; present interest-based advertising; analyze advertising performance; and communicate about products, features, offers, events, and other business-development activities.

Our marketing and advertising activities are subject to applicable law and available opt-out rights. You may opt out of marketing emails using the unsubscribe mechanism in the message. You may have additional choices concerning targeted advertising, sale, sharing, or cookies as described in Sections 8 and 9.

F. Analytics, Product Development, and Service Improvement

We use personal information, usage information, technical information, and aggregated or deidentified information to understand how the Services are used; diagnose problems; develop, maintain, improve, optimize, and measure the Services; evaluate new features; analyze performance; and protect the integrity and availability of the Services.

We may use automated tools and service providers in connection with these activities. We do not use Property Data to train artificial-intelligence or machine-learning models, and we do not sell or share Property Data with AI-model developers for model training. We do not use Property Data to make decisions that produce legal or similarly significant effects concerning housing, employment, credit, insurance, or another eligibility determination. Where we use an AI-enabled operational vendor, we intend to restrict the vendor’s use of Property Data to the applicable service purpose and prohibit independent model training or secondary use to the extent provided by our agreement with that vendor.

G. Security, Fraud Prevention, and Legal Compliance

We use personal information to detect, investigate, prevent, and respond to fraud, abuse, unauthorized access, security incidents, illegal activity, and violations of our Terms of Service or other agreements. We also use personal information to comply with legal obligations, legal process, regulatory requests, tax and accounting obligations, data-broker obligations, privacy laws, and other applicable requirements.

H. Privacy Requests and Suppression Obligations

We use personal information to receive, verify, evaluate, respond to, document, and implement privacy, deletion, correction, opt-out, suppression, and other consumer requests. We may retain limited information to maintain a suppression record, prevent future sale or licensing where required, comply with law, protect security, resolve disputes, and establish, exercise, or defend legal claims.

I. Corporate Transactions and Protection of Rights

We may use personal information to evaluate, negotiate, complete, or administer an actual or potential merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or other corporate transaction. We may also use personal information to protect the rights, property, safety, and security of Phantom Data, our Users, data subjects, and others, and to establish, exercise, or defend legal claims.

J. Additional Disclosed or Consented Purposes

We may use personal information for another purpose disclosed when the information is collected or with your consent where required by applicable law.

6. California Notice at Collection and Categories of Personal Information

This section describes the categories of personal information Phantom Data has collected or processed during the preceding twelve (12) months, the sources from which we collect it, our business or commercial purposes, the categories of recipients to whom we disclose it, and whether we sell or share it as those terms are defined by California law. We collect, use, retain, and disclose personal information only as reasonably necessary and proportionate for the purposes described in this Privacy Policy.

A. Categories of Personal Information

The following table uses the California statutory categories of personal information. It identifies whether Phantom Data collected or processed each category during the preceding twelve (12) months.

B. Sensitive Personal Information Categories

The following table uses the California statutory categories of sensitive personal information. We do not use or disclose sensitive personal information to infer characteristics about a consumer.

C. Sources of Personal Information

We collect the categories of personal information identified above from: (1) you; (2) your device, browser, and interactions with the Services; (3) our affiliates, service providers, business partners, analytics providers, advertising partners, payment processors, communications providers, and security providers; and (4) third-party data providers that supply Property Data.

D. Purposes for Collection, Use, Retention, Sale, Sharing, and Disclosure

We collect, use, retain, sell, share, and disclose personal information for the purposes described in Section 5, including to provide and improve the Services; manage accounts, Orders, plans, and transactions; license Property Data to Users; market the Services; measure advertising and usage; maintain security; comply with law; process privacy requests; and protect our rights and the rights of others.

E. Categories of Personal Information Disclosed for a Business Purpose

The following table identifies the California categories of personal information that Phantom Data disclosed for a business purpose during the preceding twelve (12) months and the categories of recipients to which the information was disclosed. These disclosures do not include Property Data licensed or sold to Users, which is addressed separately in Section 6.F.

Phantom Data did not disclose the following California categories of personal information for a business purpose during the preceding twelve (12) months: C. Protected classification characteristics under California or federal law ("Protected Classes"); E. Biometric information; and J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information").

F. Categories of Recipients and Sale or Sharing

The following table identifies the categories of personal information that Phantom Data sold or shared during the preceding twelve (12) months and the categories of recipients to which the information was sold or shared. “Sale” and “share” have the meanings given to those terms under California law.

Phantom Data does not sell or share the following California categories of personal information: C. Protected classification characteristics under California or federal law ("Protected Classes"); D. Commercial information; E. Biometric information; H. Sensory data; I. Professional or employment-related information; J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"); and L. Sensitive personal information.

The business-purpose disclosures applicable to each collected category appear in Section 6.E. We do not sell or share Property Data with government entities, law enforcement, foreign actors, or AI-model developers. We do not knowingly sell or share personal information of consumers under sixteen (16) years of age.

G. Retention Criteria

We retain each category of personal information for the period reasonably necessary to fulfill the purposes described in this Privacy Policy, including providing and supporting the Services; administering accounts, Orders, plans, payments, and promotions; complying with legal, tax, accounting, security, and data-broker obligations; processing privacy requests; resolving disputes; enforcing agreements; and protecting rights and safety. Additional retention information appears in Section 13.

7. How We Disclose Personal Information

We may disclose personal information as follows:

• To Users. We disclose Property Data to Users through the Services, subject to our Terms of Service and applicable agreements.
• To affiliates, service providers, and business partners. We may disclose personal information to affiliates and vendors that provide payment processing, hosting, cloud infrastructure, security, fraud prevention, customer support, analytics, communications, advertising, artificial-intelligence-enabled operational tools, professional, operational, and similar services. Any disclosure to an AI provider is limited to the applicable operational purpose and does not authorize the provider to train its models using Property Data.

We require service providers that process personal information on our behalf to be subject to written obligations appropriate to the services they provide. Those obligations are designed to require the provider to use personal information only to provide contracted services or as otherwise permitted by law, maintain confidentiality and appropriate security safeguards, and not sell, share, retain, use, or disclose personal information for an independent purpose inconsistent with its relationship with Phantom Data. We may use reasonable vendor-selection, oversight, and contractual measures, including appropriate downstream obligations for approved subprocessors, to help protect personal information.

• For advertising and marketing. We may disclose information about website visitors, Users, or prospective Users to advertising partners and analytics providers to market our Services, measure advertising performance, create or use audiences, and provide interest-based advertising, subject to applicable law and available opt-out rights.
• To government entities and other parties when required or appropriate. We may disclose personal information to government entities, regulators, law enforcement, courts, or other parties when required by law, legal process, or governmental request, or when we reasonably believe disclosure is necessary to protect rights, safety, security, or property; investigate fraud or misuse; or enforce our agreements.
• In connection with a corporate transaction. We may disclose personal information to a buyer, investor, lender, insurer, advisor, successor, or other participant in an actual or potential corporate transaction.
• With your consent or at your direction. We may disclose information for another purpose with your consent or at your direction.

8. Cookies, Analytics, Advertising, and Communications

We and our service providers may use cookies, pixels, web beacons, local storage, SDKs, log files, and similar technologies to operate the Services, remember preferences, keep accounts secure, understand usage, diagnose problems, measure marketing, and advertise our Services.

You may be able to control certain cookies and similar technologies through your browser or device settings. Disabling cookies may affect the availability or functionality of parts of the Services. Some browsers offer a Global Privacy Control (“GPC”) signal. Where required by applicable law, we will process a valid GPC signal as an opt-out of applicable sales, sharing, or targeted-advertising processing associated with the browser or device that transmits the signal.

We may send marketing and promotional communications by email, text message, telephone, or other lawful channels. You may opt out of marketing emails by using the unsubscribe mechanism in the message or contacting us at [email protected]. Opting out of marketing communications does not prevent us from sending transactional, account, security, legal, or other non-marketing communications.

9. Privacy Rights and Choices

Depending on your state of residence and the nature of our processing, you may have the right to request access to, correction of, deletion of, or information about personal information we maintain about you. You may also have the right to opt out of the sale or sharing of personal information, targeted advertising, or certain profiling, as applicable under state law.

Where applicable, these rights may include the right to:

• Know the categories and specific pieces of personal information we have collected about you, the sources from which we collected it, the purposes for which we collect, use, sell, share, or disclose it, and the categories of recipients to whom we disclose it;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to statutory exceptions and our ability to retain limited information for lawful purposes;
• Opt out of the sale or sharing of personal information and, where applicable, targeted advertising or certain profiling;
• Limit certain uses and disclosures of sensitive personal information where applicable; and
• Receive equal service and pricing and not be discriminated against for exercising applicable privacy rights.

The availability and scope of these rights vary by state, the information at issue, the manner in which we process it, and applicable legal exceptions.

A. Property Data: Deletion, Suppression, and Opt-Out

If you believe that your personal information is included in the Property Data available through our Services, you may request that we delete, suppress, restrict, correct, or stop selling or licensing your information by emailing [email protected] with the subject line “Privacy Request.” Please provide enough information for us to identify the information at issue and evaluate your request, such as your name, email address, telephone number, property address, mailing address, and state of residence, as applicable.

After receiving and verifying a request, we will process it as required by applicable law. Where applicable, we may suppress your information from future licensing or sale, direct our service providers and contractors to take required action, and restrict or delete information that we are not legally permitted or required to retain. We may retain limited information necessary to maintain a suppression record, comply with law, prevent fraud, protect security, resolve disputes, or establish, exercise, or defend legal claims.

California residents may also use the California Privacy Protection Agency’s accessible deletion mechanism, where available and applicable, to submit a deletion request to registered data brokers. We will process requests received through that mechanism as required by applicable law.

B. Requests Regarding Website, Account, and Other Information

To submit a request to know, access, correct, delete, obtain a portable copy of, limit, or opt out of applicable processing of personal information that we collect about you through our website, account, trial, payment, support, marketing, or other Services interactions, email [email protected] with the subject line “Privacy Request.”

C. Verification and Authorized Agents

We may take reasonable steps to verify your identity before responding to a request. The verification information we request will depend on the nature and sensitivity of the request and the information involved. We may request additional information to confirm that you are the person whose information is the subject of the request or that an authorized agent has authority to act for you.

You may use an authorized agent to submit a request where permitted by applicable law. We may require the agent to provide signed written authorization and may require you to verify your identity directly with us.

We will use personal information collected solely to verify a privacy request only for verification, request processing, fraud prevention, security, and related recordkeeping purposes. We will not use that information for unrelated marketing, sale, licensing, or other incompatible purposes, and we will retain it no longer than reasonably necessary for the verification and related lawful purposes.

D. Response Timing and Appeals

We will confirm receipt of a request and respond within the time required by applicable law. If we need additional time, we will notify you where required. If we deny all or part of a request, we will explain the basis for the denial to the extent required or permitted by law.

If you are entitled to appeal a decision regarding your privacy request, you may submit an appeal by emailing [email protected] with the subject line “Privacy Request Appeal.” We will review the appeal and respond as required by applicable law.

We will not discriminate against you for exercising privacy rights available under applicable law.

10. Additional Data-Broker and State-Specific Disclosures

A. Data-Broker Practices

Phantom Data licenses or sells property-owner and contact information to Users through the Services. We obtain brokered data from third-party data providers. We do not independently collect, create, enrich, score, verify, or add to the Property Data records made available through the Services.

We do not currently implement a formal purchaser credentialing or know-your-customer process for ordinary Users. We may, however, request information, verify accounts, limit access, or suspend or terminate access as permitted by our Terms of Service.

We do not knowingly collect or process brokered personal information about known minors. We have not experienced a security breach involving personal information during the preceding year.

Individuals may request to opt out of all or a portion of Phantom Data’s sale or licensing of brokered personal information by submitting a request under Section 9. We permit authorized agents to submit requests where required by applicable law and subject to reasonable verification.

An opt-out, suppression, or deletion request may not apply to information that Phantom Data must retain or process for a lawful purpose, including legal compliance, fraud prevention, security, or maintaining a record of the request and suppression preference. We will explain applicable limitations when required by law.

B. California Privacy Rights

California residents may have the right to know the categories and specific pieces of personal information we collect; the sources of that information; the business or commercial purposes for collection, use, disclosure, sale, or sharing; and the categories of recipients. California residents may also have rights to request deletion, correction, and, where applicable, to opt out of the sale or sharing of personal information or limit certain uses of sensitive personal information.

California residents may exercise applicable rights through the procedures in Section 9. The California category, source, purpose, recipient, sale, sharing, and retention disclosures required for our Privacy Policy are included in Section 6.

C. Texas Data-Broker Notice

THE ENTITY MAINTAINING THIS WEBSITE IS A DATA BROKER UNDER TEXAS LAW. TO CONDUCT BUSINESS IN TEXAS, A DATA BROKER MUST REGISTER WITH THE TEXAS SECRETARY OF STATE (TEXAS SOS). INFORMATION ABOUT DATA BROKER REGISTRANTS IS AVAILABLE ON THE TEXAS SOS WEBSITE.

D. Vermont Data-Broker Notice

Phantom Data is registered or will register as a data broker in Vermont as required by applicable law. Vermont residents may use the procedures in Section 9 to request available opt-out choices concerning brokered personal information.

E. Oregon Data-Broker Notice

Oregon residents may use the procedures in Section 9 to request available opt-out choices concerning the collection, sale, or licensing of brokered personal data. We will process requests and authorized-agent submissions as required by applicable law.

11. How We Protect Personal Information

We maintain a written information-security program designed to protect personal information in a manner appropriate to the nature of our business, the volume and sensitivity of personal information we process, the risks reasonably foreseeable to that information, and applicable legal requirements. Our program is designed to include administrative, technical, and physical safeguards.

Our safeguards may include, as appropriate:

• Designating personnel responsible for maintaining and administering information-security practices;
• Identifying, assessing, and addressing reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of personal information;
• Restricting access to personal information to personnel and service providers with a legitimate need to know;
• Authentication and account-security controls, including controls designed to protect credentials and restrict access to active accounts;
• Encryption or other safeguards for personal information in transit and, where appropriate, at rest;
• Logging, monitoring, malware protection, security updates, and other measures designed to detect or prevent unauthorized access, misuse, or system failure;
• Training and requiring personnel to comply with applicable security policies and procedures;
• Vendor-selection, oversight, and contractual measures designed to require service providers to maintain appropriate safeguards;
• Incident-response procedures, including investigation, containment, remediation, documentation, and post-incident review; and
• Periodic review of the security program and safeguards, including following material changes in our business practices that may affect the security or integrity of personal information.

No system, website, transmission, or storage method is completely secure. You should use caution when transmitting information to us through email, text message, or other communications channels.

12. How Long We Retain Personal Information

We retain personal information for as long as reasonably necessary to provide and support the Services; administer accounts, Orders, plans, payments, and promotions; comply with legal, regulatory, tax, accounting, security, and data-broker obligations; process privacy requests; resolve disputes; enforce agreements; and protect our rights and the rights of others.

More specifically, our retention criteria include the following:

• Account, authentication, and business-contact information is retained while an account is active and afterward for a period reasonably necessary for account administration, security, legal compliance, dispute resolution, fraud prevention, and enforcement of our agreements.
• Trial, Order, payment, subscription, credit, refund, chargeback, and transaction records are retained for the period reasonably necessary for transaction administration, accounting, tax, audit, security, fraud prevention, payment disputes, and legal compliance.
• Communications, support requests, and recordings are retained for the period reasonably necessary to respond to the communication, administer the account or Services, improve support, maintain quality assurance, protect security, resolve disputes, and establish, exercise, or defend legal claims.
• Website, device, cookie, analytics, advertising, and usage information is retained for the period reasonably necessary to operate, secure, analyze, improve, market, and measure the Services and advertising, subject to applicable opt-out choices and legal requirements.
• Property Data is retained for the period reasonably necessary to provide the Services, comply with source, legal, privacy, security, and data-broker obligations, process suppression or consumer-rights requests, and maintain appropriate records. Property Data may be refreshed, corrected, restricted, suppressed, deleted, or made unavailable in accordance with applicable law, a valid consumer request, or our operational requirements.
• Privacy-request, verification, deletion, opt-out, correction, and suppression records are retained for the period reasonably necessary to process and document the request, prevent re-sale or re-licensing where required, comply with law, protect security, and establish, exercise, or defend legal claims.
• Security, incident-response, audit, and compliance records are retained for the period reasonably necessary to investigate, remediate, document, and improve security and compliance practices and meet applicable legal obligations.
• Backup and archival records may be retained for a limited period under our backup, business-continuity, and disaster-recovery practices, subject to applicable safeguards and deletion or overwriting cycles.

Retention periods vary based on the information’s nature, sensitivity, volume, source, purpose, legal requirements, and the risks associated with retaining or deleting it. We may retain limited information after a deletion or opt-out request where necessary to maintain a suppression record, prevent the future sale or licensing of the information, comply with law, protect security, or establish, exercise, or defend legal claims. When we no longer need personal information, we will delete, destroy, deidentify, or aggregate it in accordance with our practices and applicable law.

13. International Users

Our Services are intended for use in the United States. If you access the Services from outside the United States, you understand that your information may be processed in the United States and other locations where Phantom Data or its service providers operate, subject to applicable law.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on the Services and revise the “Last Updated” date. If we make a material change, we will provide additional notice when required by applicable law. Your continued use of the Services after the effective date of an updated Privacy Policy is subject to the updated policy.

15. Contact Information

If you have questions about this Privacy Policy or our privacy practices, or if you wish to submit a privacy request, please contact us at:

Phantom Data LLC
Address: 2125 Biscayne Blvd, Ste 204 #17546, Miami, FL 33137
Email: [email protected]