Privacy Policy & Notice
1. Introduction
Phoenix Investors (“we,” “us,” or “our”) is committed to protecting your privacy and ensuring the lawful and transparent processing of personal data.
This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit https://phoenixinvestors.com (“the Service”).
It is designed to comply with:
- The EU General Data Protection Regulation (GDPR)
- Relevant U.S. state privacy laws (including the California Consumer Privacy Act as amended by the CPRA, and similar laws in Virginia, Colorado, Connecticut, and Utah).
By using our website, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller and EU Representative
The data controller responsible for processing your personal data is:
Phoenix Investors
401 E Kilbourn Ave, Ste 201
Milwaukee, WI 53202
United States
Email: info@phoenixinvestors.com
Phone: (414) 283-2600
Phoenix Investors also serves as its EU Representative under Article 27 of the GDPR for data subjects and supervisory authorities in the European Union.
EU residents may contact Phoenix Investors at the same address and contact information listed above for any GDPR-related inquiries.
3. Personal Data We Collect
Data may be transferred to and processed in the United States. We collect and process the following categories of personal information:
- Identification and contact information: name, email address, phone number.
- Technical and usage data: IP address, device and browser information, access dates, pages visited, and cookie-related data.
- Marketing and communications data: preferences, interactions with our website or email communications.
We do not intentionally collect sensitive personal data through this site.
4. How We Use Personal Data and Legal Bases (GDPR)
We process personal data only where we have a lawful basis.
| Purpose | Example Activities | Lawful Basis |
|---|---|---|
| Providing and improving the website | Contact forms, support requests, security monitoring | Legitimate interest (Art. 6(1)(f)) |
| Marketing and promotional communications | Sending newsletters and updates | Consent (Art. 6(1)(a)) |
| Customer support | Responding to inquiries, troubleshooting | Legitimate interest or contract performance (Art. 6(1)(f) / 6(1)(b)) |
| Security and fraud prevention | Logging, IP monitoring, DDoS protection | Legitimate interest (Art. 6(1)(f)) |
| Compliance with legal obligations | Responding to lawful requests | Legal obligation (Art. 6(1)(c)) |
You may withdraw your consent at any time.
5. How We Collect Information
- Directly from you when you provide it (e.g., forms, subscriptions)
- Automatically through cookies and similar technologies (see our Cookie Policy)
- Through analytics and security tools (e.g., Google Analytics, Cloudflare)
- We implement reasonable administrative, technical, and physical safeguards to protect personal information.
- This website is not directed to children under 13 and we do not knowingly collect personal information from children.
6. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy.
| Data Category | Retention Period |
|---|---|
| Contact and inquiry data | Up to 24 months after last interaction |
| Marketing and consent records | Up to 24 months or until consent is withdrawn |
| Technical and analytics data | Up to 14 months |
| Legal/compliance data | As required by law |
When retention periods expire, personal data is securely deleted or anonymized.
7. International Data Transfers
Because we are located in the United States, personal data collected from EU/EEA users may be transferred outside the EEA.
We ensure adequate safeguards under Chapter V of GDPR, including:
- European Commission adequacy decisions (if applicable)
- Standard Contractual Clauses (SCCs)
- Additional security measures
You can request more information about these safeguards at info@phoenixinvestors.com.
8. Sharing of Personal Data
We do not sell personal information. We may share data with:
- Service providers who help us operate our website (e.g., hosting, analytics, security, email communications)
- Regulatory or legal authorities when required by law
- Professional advisers (e.g., legal or compliance consultants)
All third-party processors operate under legally binding agreements and GDPR Article 28 standards.
9. Your Rights (EU & U.S.)
EU/EEA Data Subject Rights (GDPR Articles 15–22)
- Right to access your data
- Right to rectify inaccuracies
- Right to erase data (“right to be forgotten”)
- Right to restrict or object to processing
- Right to data portability
- Right to withdraw consent at any time
- Right to lodge a complaint with your local supervisory authority
U.S. State Privacy Rights (e.g., CCPA/CPRA)
Residents of certain U.S. states may have the right to:
- Know the categories and specific pieces of personal information we collect
- Request deletion or correction of personal information
- Opt out of the sale or sharing of personal information
- Limit the use of sensitive personal information (if collected)
- Designate an authorized agent to exercise rights on their behalf
We do not sell or share personal information as defined under the California Consumer Privacy Act (CCPA/CPRA).
To exercise these rights, email info@phoenixinvestors.com. We may request information to verify your identity.
10. Verification & Authorized Agents (U.S.)
When a privacy rights request is submitted, we may verify your identity using information you previously provided (e.g., email confirmation or other verification methods).
If you are a California resident, you may authorize an agent to submit requests on your behalf. We require proof of the agent’s authorization and verification of your identity.
11. Automated Decision-Making
We do not use personal data for automated decision-making or profiling that produces legal or significant effects.
If this changes, we will update this policy and provide notice in advance.
12. Children’s Privacy
Our website and services are not directed to children under 13 years of age.
We do not knowingly collect personal information from children. If we learn that a child has provided personal data, we will delete it promptly.
13. Security of Your Information
We use appropriate technical and organizational measures to protect personal data, including:
- SSL encryption
- Access controls and authentication
- Data minimization and secure storage
- Staff training on data protection
However, no system is entirely secure. We encourage users to protect their personal information when online.
14. Updates to This Policy
We may update this Privacy Policy periodically.
When we make material changes, we will update the “Last Updated” date and, where appropriate, notify you via the website or email.
The revised policy becomes effective upon posting.
15. Contact Information
If you have any questions or concerns about this Privacy Policy, or wish to exercise your rights, please contact:
Phoenix Investors
401 E Kilbourn Ave, Ste 201
Milwaukee, WI 53202
United States
Email: info@phoenixinvestors.com
Phone: (414) 283-2600
Phoenix Investors also serves as its EU Representative under Article 27 of the GDPR. EU residents may contact Phoenix Investors at the same address and contact information for any GDPR-related inquiries.
EU residents may also lodge a complaint with their local data protection authority:
https://www.edpb.europa.eu/home_en
16. Privacy Notice to All Data Subjects
This section serves as Phoenix Investors’ privacy notice to all individuals whose personal information we collect or process. It applies regardless of whether the information is collected through our website, by email, by telephone, in person, through a business relationship, from a third party, or by other lawful means.
Data subjects covered by this notice may include:
- Website visitors and individuals submitting online inquiries
- Prospective, current, and former tenants or occupants
- Investors, prospective investors, and their representatives
- Property owners, purchasers, sellers, brokers, and transaction participants
- Vendors, contractors, consultants, service providers, and business partners
- Job applicants, employees, former employees, and personnel representatives
- Government, community, media, and professional contacts
- Individuals communicating or otherwise interacting with Phoenix Investors
- Other individuals whose personal information Phoenix Investors lawfully receives or processes
17. Categories of Personal Information
Depending on the nature of your relationship or interaction with Phoenix Investors, we may collect the following categories of personal information:
- Identifiers and contact information, such as your name, business name, job title, mailing address, email address, telephone number, and online identifiers
- Professional, employment, and business information, such as your employer, occupation, professional history, qualifications, business affiliations, and communications
- Commercial and relationship information, such as leasing inquiries, property interests, transaction history, service requests, contracts, and records relating to our business relationship
- Financial or transaction-related information when necessary for a proposed or existing transaction, lease, investment, vendor relationship, or other business purpose
- Internet, device, and electronic activity information, such as IP address, browser type, device information, website activity, referring pages, cookies, and analytics information
- Communications and records, including emails, telephone communications, correspondence, meeting information, submitted documents, and information included in forms or requests
- Employment and applicant information, where applicable, such as resumes, employment history, qualifications, references, and other recruitment-related information
- Security and access information, such as building access records, fraud-prevention information, system logs, and security-related communications
- Any other personal information you voluntarily provide or that we lawfully obtain in connection with our operations
Phoenix Investors does not intentionally request sensitive personal information through its general website forms. Sensitive information should not be submitted unless it is specifically requested and reasonably necessary for a legitimate business, employment, legal, security, or transactional purpose.
18. Sources of Personal Information
We may obtain personal information:
- Directly from you
- From your employer, representative, broker, adviser, or authorized agent
- Through our website, forms, email communications, telephone calls, meetings, and other interactions
- From property records, government records, professional directories, public databases, and other publicly available sources
- From service providers, business partners, vendors, analytics providers, security providers, and professional advisers
- In connection with transactions, leases, investments, employment matters, legal proceedings, due diligence, or business operations
19. Purposes for Collecting and Processing Information
We may collect, use, and process personal information to:
- Respond to inquiries and communicate with you
- Evaluate, establish, administer, or manage business relationships
- Market, lease, purchase, sell, develop, finance, or manage properties
- Conduct due diligence and evaluate prospective transactions
- Process applications, proposals, contracts, leases, payments, and related documentation
- Manage investor, tenant, vendor, contractor, employee, and applicant relationships
- Operate, maintain, secure, and improve our website, systems, properties, and business operations
- Provide information, updates, marketing communications, and other requested materials
- Detect, investigate, and prevent fraud, security incidents, misuse, and unlawful activity
- Establish, exercise, or defend legal claims
- Comply with contractual, regulatory, tax, reporting, insurance, and legal obligations
- Complete a merger, acquisition, financing, reorganization, asset sale, or other corporate transaction
- Carry out other purposes disclosed to you at the time information is collected or as otherwise permitted by law
Where applicable, Phoenix Investors processes personal information based on consent, performance of a contract, compliance with legal obligations, protection of legitimate interests, or another lawful basis recognized under applicable law.
20. Disclosure of Personal Information
We may disclose personal information to affiliated companies, property managers, lenders, investors, professional advisers, technology providers, hosting providers, analytics providers, communications providers, security providers, government authorities, transaction participants, and other parties when reasonably necessary for the purposes described in this Privacy Policy and Notice.
We may also disclose information when required by law, to protect legal rights or safety, to investigate suspected misconduct, or in connection with a corporate or real estate transaction.
Phoenix Investors does not sell personal information for monetary compensation. Where applicable law defines “sale,” “sharing,” or “targeted advertising” more broadly, individuals may exercise any available opt-out rights using the contact information provided below or through any privacy preference mechanism made available on our website.
21. Retention
Personal information is retained only for as long as reasonably necessary to fulfill the purposes for which it was collected, maintain appropriate business and transaction records, comply with legal or contractual obligations, resolve disputes, enforce agreements, and protect Phoenix Investors’ legitimate interests.
Retention periods may vary based on the type of information, the relationship involved, applicable legal requirements, and the continued need for the information.
22. Your Choices and Rights
Depending on your location and applicable law, you may have rights regarding access, correction, deletion, restriction, objection, portability, withdrawal of consent, and opting out of certain uses or disclosures of personal information.
Requests may be submitted to:
Phoenix Investors
401 E Kilbourn Ave, Ste 201
Milwaukee, WI 53202
Email: info@phoenixinvestors.com
Phone: (414) 283-2600
We may verify your identity and authority before processing a request. Additional information about privacy rights, verification procedures, international transfers, security, retention, and contacting regulatory authorities is provided in the remaining sections of this Privacy Policy and Notice.
