Who We Are and What This Policy Covers

Twinbrook Capital, Inc. dba Phase 2 Leadership (“Phase 2 Leadership,” “we,” “us,” or “our”) is a United States corporation. Throughout this Privacy Policy we’ll refer to our website and other products and services collectively as “Services.”

Information We Collect

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

  • Basic Account Information: For certain Services, we ask for basic information from you in order to set up your account.
  • Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile.
  • Transaction and Billing Information: If you buy something from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
  • Communications With Us: You may also provide us information when you respond to surveys or communicate with us via email or a contact form.
  • Comments: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment. Visitor comments may be checked through an automated spam detection service.
  • Media: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Information We Collect Automatically

We also collect some information automatically:

  • Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
  • Usage Information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views) along with information about your device. We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
  • Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We utilize Google Analytics to collect information about your usage of our websites and we make every effort to request and maintain IP address anonymization.
  • Cookies: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
    If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
  • Embedded content from other websites: Pages and articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
    These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
How And Why We Use Information
Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

  • To provide our Services;
  • To further develop and improve our Services;
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition;
  • To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of us and others, which may result in us declining a transaction or the use of our Services;
  • To communicate with you, for example through an email, about offers and promotions offered by us and others we think will be of interest to you, solicit your feedback, or keep you up to date on us and our products; and
  • To personalize your experience using our Services.
Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or (5) You have given us your consent.

Sharing Information
How We Share Information

We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

  • Employees and Independent Contractors: We may disclose information about you to our employees and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our employees and independent contractors to follow this Privacy Policy for personal information that we share with them.
  • Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), and those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them.
  • Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
  • With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.
  • Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you.
How Long We Keep Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

  • Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
  • Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
  • Set Your Browser to Reject Cookies: At this time, we not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using our websites, with the drawback that certain features of our websites may not function properly without the aid of cookies.
  • Close Your Account: If you no longer want to use our Services, you can close your account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us. EU individuals also have the right to make a complaint to a government supervisory authority.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us.

Privacy Policy Changes

Although most changes are likely to be minor, we may change our Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to our Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice . Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Updated: June 4, 2018