COOKIE POLICY
THE PHOENIX GROUP, INC.

1. INTRODUCTION

Thank you for visiting The Phoenix Group, Inc. ("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. This Cookie Policy explains how we use cookies and similar tracking technologies when you visit our website [teamphoenix.com] ("Site"), your choices regarding these technologies, and your rights concerning the personal information collected through them.

This Cookie Policy is part of our overall Terms and Conditions and Privacy Policy for using the Site. By using our Site, you acknowledge that you have read and understood this Cookie Policy.

If you have any questions or concerns about this Cookie Policy or our data practices, please contact us at:

The Phoenix Group, Inc.
164 S. Park Blvd.
Greenwood, IN 46143
Email: hrdept@teamphoenix.com
Phone: 317-884-3600

2. WHAT ARE COOKIES?

Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. Cookies allow the website to recognize your device and remember information about your visit, such as your preferences, settings, and browsing activity.

We also use similar tracking technologies, including:

1. Pixel tags/web beacons: Small graphic images embedded in web pages or emails that track whether you have opened an email or visited a page.
2. ‍Local storage: Technology that allows websites to store data locally on your device.
3. Session storage: Similar to local storage but data is cleared when the browser session ends.
4. Device fingerprinting: Collection of information about your device configuration to identify your device across sessions.

For simplicity, we refer to all these technologies collectively as "cookies" in this policy.

3. CATEGORIES OF COOKIES WE USE

We classify the cookies used on our Site into the following categories:

3.1 Strictly Necessary Cookies

These cookies are essential for the basic functioning of our Site. They enable core functionality such as security, network management, accessibility, and navigation. Without these cookies, services you have requested cannot be provided. These cookies do not gather information about you for marketing purposes or remember where you have been on the internet.

Legal Basis for Processing: These cookies are necessary for the performance of our contract with you to provide the Site and its services, and for our legitimate interests in operating a functional and secure website.

3.2 Functional Cookies

These cookies enable enhanced functionality and personalization, such as remembering your preferences, language settings, or region. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these features may not function properly.

Legal Basis for Processing: We process this data based on your consent, which you may withdraw at any time.

3.3 Analytics and Performance Cookies

These cookies collect information about how visitors use our Site, such as which pages are visited most often and whether visitors receive error messages. These cookies collect aggregated, statistical information that does not directly identify individual visitors. We use this information to improve how our Site works and to understand user behavior.

Legal Basis for Processing: We process this data based on your consent, which you may withdraw at any time.

For more information about Google Analytics cookies, please visit: https://policies.google.com/privacy

3.4 Advertising and Targeting Cookies

These cookies are used to deliver advertisements that are relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to measure the effectiveness of advertising campaigns. These cookies remember that you have visited our Site and this information may be shared with advertising partners.

Important Notice: We may use these cookies to display targeted advertising based on your browsing activity across websites and online services over time. This practice is sometimes called "cross-context behavioral advertising" or "targeted advertising." You have the right to opt out of this type of advertising.

Legal Basis for Processing: We process this data based on your consent, which you may withdraw at any time.

4. PERSONAL INFORMATION COLLECTED THROUGH COOKIES

Through our use of cookies and similar technologies, we may collect the following categories of personal information:

1. Identifiers: Device identifiers, IP addresses, cookie IDs, advertising identifiers, and unique online identifiers.‍
2. Internet or Electronic Network Activity Information: Browsing history on our Site, search queries, interactions with our Site and advertisements, pages visited, time spent on pages, click-through data, and referring URLs.
3. Geolocation Data: Approximate location derived from IP address (we do not collect precise geolocation through cookies without separate consent).
4. Inferences: Information derived from your browsing activity to create a profile reflecting your preferences, interests, and behavior.

5. HOW WE USE INFORMATION COLLECTED THROUGH COOKIES

We use information collected through cookies for the following purposes:

1. Essential Site Operations: To ensure the Site functions correctly and securely.
2. Remembering Your Preferences: To remember your settings, language preferences, and login information.
3. Analytics and Improvement: To understand how visitors interact with our Site and to improve our Site's functionality, content, and user experience.
4. Advertising and Marketing: To deliver relevant advertisements and measure their effectiveness. This includes targeted advertising based on your interests derived from your browsing activity.
5. Security: To detect and prevent fraud, unauthorized access, and other malicious activity.
6. Legal Compliance: To comply with applicable laws and regulations.

6. SHARING OF INFORMATION COLLECTED THROUGH COOKIES

We may share personal information collected through cookies with the following categories of third parties:

1. Service Providers and Processors: Companies that perform services on our behalf, such as website hosting, analytics, and advertising services. These parties are contractually obligated to use your information only for the purposes we specify.
2. Advertising Partners: Third-party advertising networks and platforms that help us deliver targeted advertising. These partners may use the information to show you ads on other websites.
3. Analytics Providers: Companies like Google that help us understand how our Site is used.
4. Social Media Platforms: When you interact with social media features on our Site.
5. Affiliates: Our subsidiary and affiliated companies within The Phoenix Group corporate family.
6. Legal and Safety: When required by law, court order, or governmental authority, or when necessary to protect our rights, safety, or property.
7. Business Transfers: In connection with a merger, acquisition, or sale of assets.

Disclosure Regarding Sale and Sharing: We may share certain information collected through cookies with advertising partners in ways that may constitute a "sale" or "sharing" of personal information under applicable privacy laws. This includes sharing identifiers and internet activity information with advertising networks for targeted advertising purposes. You have the right to opt out of this sale or sharing.

7. INTERNATIONAL DATA TRANSFERS

Personal information collected through cookies may be transferred to, stored, and processed in countries other than the country in which you reside, including the United States. These countries may have data protection laws that differ from the laws of your country.

When we transfer personal information internationally, we implement appropriate safeguards to protect your information, including:

1. Standard contractual clauses approved by relevant authorities
2. Data processing agreements with our service providers
3. Other legally recognized transfer mechanisms

If you would like more information about these safeguards or to obtain a copy, please contact us using the information provided below.

8. DATA RETENTION

We retain personal information collected through cookies for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law.

Specific retention periods for cookies are listed in the cookie tables in Section 3 above. After a cookie expires, we retain any personal information collected through that cookie only as necessary for:

1. Legal compliance and record-keeping
2. Resolving disputes
3. Enforcing our agreements
4. Other legitimate business purposes

9. YOUR RIGHTS AND CHOICES

9.1 Cookie Consent and Preferences

When you first visit our Site, you will be presented with a cookie consent banner that allows you to:

1. Accept All Cookies: Consent to all categories of cookies
2. Reject Non-Essential Cookies: Accept only strictly necessary cookies
3. Customize Your Preferences: Choose which categories of cookies to accept or reject

You can change your cookie preferences at any time by clicking on the "Cookie Settings" link in the footer of our Site or by contacting us.

Withdrawing Consent: You have the right to withdraw your consent to non-essential cookies at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw consent, adjust your cookie preferences using the methods described above.

9.2 Browser Settings

Most web browsers allow you to manage your cookie preferences through browser settings. You can typically:

1. View what cookies are stored on your device
2. Delete cookies individually or in bulk
3. Block cookies from specific or all websites
4. Block third-party cookies
5. Clear all cookies when you close your browser
6. Set your browser to notify you when cookies are being set

Please note that if you block or delete cookies, some features of our Site may not function properly.

For information on managing cookies in common browsers:

1. Chrome: https://support.google.com/chrome/answer/95647‍
2. Firefox: https://support.mozilla.org/kb/cookies-information-websites-store-on-your-computer‍
3. Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471‍
   
4. Edge: https://support.microsoft.com/microsoft-edge/delete-cookies-in-microsoft-edge

9.3 Opt-Out Preference Signals

‍We honor opt-out preference signals, including the Global Privacy Control (GPC). When we detect such a signal from your browser or device, we will treat it as a valid request to opt out of the sale or sharing of your personal information and targeted advertising for that browser or device. To learn more about GPC, visit: https://globalprivacycontrol.org/

9.4 Do Not Track

‍Some browsers include a "Do Not Track" (DNT) feature that sends a signal to websites requesting that your browsing activity not be tracked. Because there is no common industry standard for DNT, we do not currently respond to DNT signals. However, we do honor GPC signals as described above.

9.5 Opt Out of Targeted Advertising and Sale/Sharing of Personal Information

‍You have the right to opt out of:

1. Targeted Advertising: The use of your personal information for advertising based on your activity across different websites and services over time.
2. Sale or Sharing of Personal Information: The disclosure of your personal information to third parties for monetary or other valuable consideration, or for cross-context behavioral advertising.

‍To exercise your right to opt out:‍

1. Adjust your cookie preferences via our Cookie Settings
2. Enable GPC or a similar opt-out preference signal in your browser
3. Contact us using the information provided below

Please note that if you opt out, you may still see advertisements, but they will be less relevant to your interests.

9.6 Your Personal Information Rights

‍Depending on your location, you may have additional rights regarding the personal information we collect through cookies, including:

1. Right to Know/Access: You have the right to request confirmation of whether we are processing your personal information and to access the specific pieces of personal information we have collected about you.
2. Right to Correction: You have the right to request correction of inaccurate personal information we maintain about you.
3. Right to Deletion: You have the right to request deletion of personal information we have collected about you, subject to certain exceptions.
4. Right to Portability: You have the right to receive a copy of your personal information in a portable, readily usable format.
5. Right to Opt Out: As described above, you have the right to opt out of the sale or sharing of your personal information and targeted advertising.
6. Right to Restrict Processing: You have the right to request restriction of processing of your personal information in certain circumstances.
7. Right to Object: You have the right to object to processing of your personal information for certain purposes.
8. Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

‍How to Exercise Your Rights:

‍To exercise any of these rights, please:

1. Email us at: hrdept@teamphoenix.com
2. Call us at: 317-884-3600

We will respond to your request within 45 days. If we need additional time, we will inform you of the reason and extension period in writing. If we cannot verify your identity or authority to make the request, we may request additional information.

9.7 Authorized Agents

‍You may designate an authorized agent to make a request on your behalf. To do so, you must provide the authorized agent with written permission and we may require you to verify your own identity directly with us.

9.8 Appeal Process

‍If we decline to take action on your request, you have the right to appeal our decision. To appeal, please contact us at [hrdept@teamphoenix.com] within a reasonable time after receiving our decision. Include "Appeal" in the subject line and provide:

1. Your name and contact information
2. A description of the request you made
3. The reason you believe our decision was incorrect
4. Any supporting documentation

We will respond to your appeal within 60 days. If we deny your appeal, we will provide you with information on how to contact the appropriate regulatory authority to submit a complaint.

10. CHILDREN'S PRIVACY

Our Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 through cookies or otherwise. If we learn that we have collected personal information from a child under 13, we will delete that information promptly. If you believe we have collected personal information from a child under 13, please contact us immediately.

11. THIRD-PARTY WEBSITES AND SERVICES

Our Site may contain links to third-party websites, applications, or services. This Cookie Policy does not apply to those third-party sites. We encourage you to review the privacy policies and cookie policies of any third-party sites you visit.

12. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

1. Update the "Last Updated" date at the top of this policy
2. Provide notice through our Site or other appropriate means
3. Obtain your consent again where required by applicable law

We encourage you to review this Cookie Policy periodically to stay informed about our use of cookies.

13. ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

‍13.1 Residents of Certain U.S. States

‍If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Indiana, or other states with comprehensive privacy laws, you may have additional rights as described in Section 9 above. These rights include the right to know, access, correct, delete, and port your personal information, as well as the right to opt out of sales, sharing, and targeted advertising.

To exercise these rights, please use the methods described in Section 9.6.

‍13.2 Residents of the European Economic Area, United Kingdom, and Switzerland

‍If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal information based on the following legal grounds:

1. Consent: For non-essential cookies (analytics, advertising, social media), we rely on your consent. You can withdraw consent at any time.
2. Legitimate Interests: For certain analytics purposes, we may rely on our legitimate interests in understanding how our Site is used and improving our services, balanced against your rights.
3. Contract Performance: For strictly necessary cookies, processing is necessary to provide you with the Site and its services.

You have additional rights including the right to lodge a complaint with your local data protection authority.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Cookie Policy or our data practices, please contact us:

‍The Phoenix Group, Inc.
Attn: Privacy Officer
‍164 S. Park Blvd.
Greenwood, IN 46143
‍Email: hrdept@teamphoenix.com

For matters specifically related to cookies and tracking technologies, you may also contact us at: hrdept@teamphoenix.com

‍Effective Date: February 9, 2026