The Privacy Policy of Pharos Systems International
[last reviewed and updated: April 02, 2026]
This Privacy Policy explains how Pharos Systems International (“Pharos,” “we,” “us,” or “our”) collects, uses, and discloses your personal information and what rights you may have with respect to your personal information. Pharos is the controller of the data described in this Privacy Policy. This Privacy Policy describes how we process personal information collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.
This Privacy Policy applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions. However, this Privacy Policy does not apply to our current/former employees, job applicants, and other individuals who interact with us for employment-related purposes. This Privacy Policy also does not apply to data that we handle on behalf of and under the instructions of our business customers.
If you are a California resident, please click here for more information about your privacy rights.
If you are a resident of the EU/ EEA or the United Kingdom, please click here for more information about your privacy rights.
I. Collection And Use Of Personal Information
What Personal Information We Collect:
Depending on the products and services you use, we may collect, use and store different kinds of personal information from or about you:
- Personal identifiers, including name, title, company name, job function, expertise, postal address, telephone number, email address, username or display name, and device identifiers (e.g., IP address).
- Records about you, such as the content, timing and method of communications you have with us, such as online chats, calls, and emails; information you share with or upload to your social media profile or our Digital Properties, such as reviews and comments; travel and scheduling information; and food preferences.
- Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information, please see our Cookie Policy.
- Inferences drawn from personal information, such as information about your interests or purchase preferences.
- Non-precise geolocation data, such as your location as derived from your IP address.
- Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings when you attend a Pharos event or communicate with us.
- Sensitive Personal Information, specifically information about your health, such as allergies or accessibility requests. We use your Sensitive Personal Information only for legitimate business purposes, including to (i) perform services or provide goods reasonably expected by an average person; (ii) detect security incidents; (iii) resist malicious, deceptive or illegal actions; (iv) ensure the physical safety of individuals; (v) for short-term, transient use; (vi) perform or provide internal business services; or (vii) verify or maintain the quality or safety of a service or device. We do not sell your Sensitive Personal Information. If you are based in the EEA/UK, we will not process any Sensitive Personal Information, without your consent.
How We Collect Personal Information
- Information you provide: We may collect the personal information you provide when you register and use our products and services, visit our Digital Properties, participate in the Pharos Help Center, contact us, sign up to receive our marketing communications, request a demo, register for a webinar, subscribe to our email newsletter, download content (e.g., whitepapers), interact with us at in-person events, or otherwise interact with us.
- Information collected automatically and through cookies: We may automatically collect information or inferences about you; such as through cookies, pixels, tags, scripts, and other tracking technologies (collectively, “Cookies”), when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information. For more information about cookies please see our Cookie Policy.
- Information from third parties: We may also collect information from third parties, including affiliated companies and subsidiaries, business partners, marketing agencies, social media companies, and service providers.
- Information from public sources: We may collect information from publicly available sources, such as public profiles and websites.
II. How We Use Your Personal Information
Depending on the nature of our relationship with you, we may use personal information for the purposes described below:
| Purposes | Legal bases (applicable only if you are based in the EEA and UK) |
| Provide and deliver products or services, including software updates | Performance of the contract entered with you |
| Operate and improve our operations, systems, products, and services | Performance of the contract entered with you.
Legitimate interest of Pharos to operate and improve our operations, systems, products, and services |
| Understand you and your preferences to enhance your experience | Legitimate interest of Pharos to enhance your experience |
| Respond to your comments and questions, fulfill your requests, and provide customer service | Depending on the nature of our relationship:
– Either performance of the contract entered with you (if you are an existing customer) – Or take steps prior to entering into a contract (if you are a potential customer) |
| Send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages (transactional information) | Performance of the contract entered with you |
| Communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by Pharos and our selected partners | Legitimate interest of Pharos to develop its business activities (with your prior consent when required by applicable laws).
Your consent. |
| Our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Digital Properties, products, and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities | Legitimate interest of Pharos to analyze data; conduct audits; perform fraud monitoring and prevention; develop new products; enhance, improve or modify our Digital Properties, products, and services; identify usage trends; determine the effectiveness of our promotional campaigns; and operate and expand our business activities |
| Targeted advertising and personalizing your user/customer experience | Legitimate interest of Pharos to engage in targeted advertising and personalize your user/customer experience (with your consent when required by applicable laws) |
| Send you marketing communications, including email in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you | Legitimate interest of Pharos to engage in promotional activities for developing our business activities (with your consent when required by applicable laws) |
| Enforce our terms and conditions or protect our business, partners, or user | Legitimate interest of Pharos in protecting the rights and interests of our business, partners, and users |
| Protect against, investigate, and deter fraudulent, unauthorized, or illegal activity | Legitimate interest of Pharos in protecting against fraudulent, unauthorized, or illegal activity |
| Compliance with legal and regulatory obligations | Legal and regulatory obligations to which Pharos is subject |
| Corporate transaction management | Legitimate interest of Pharos in transferring business activities or assets (with your consent when required by applicable laws) |
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
For any of the uses of your personal information described above that require your consent under applicable law, you may withdraw your consent at any time by contacting us as described in the “Contact Us” section below.
III. Disclosure Of Personal Information
Each category of personal information that we collect may be disclosed to the recipients described below for the purposes described in this Privacy Policy.
Our Service Providers, Suppliers, and Other Partners
We may disclose personal information to service providers, suppliers, and other partners for operational and technical purposes related to our products and services including the management of our relationship with you, such as website hosting; email services; marketing; advertising; auditing; payment processing; fulfilling customer orders; data analytics; providing customer support; conducting customer research and satisfaction surveys; cloud storage services; and other services that assist in providing or selling our products and services.
Advertising and Analytics Partners
We may disclose your personal information to advertisers, data analytics providers, and social media networks, which assist us with making product recommendations, marketing messaging, and sending you relevant content.
Corporate Affiliates
We disclose personal information to our affiliates and subsidiaries for the global management of our business activities, to the extent permitted by law.
Corporate Business Transactions
In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal information to the relevant third party.
Regulatory Authorities, Law Enforcement, and Compliance with Law
It may be necessary—by law or as a result of legal process, litigation, or requests from competent authorities within or outside your country of residence (e.g., public or governmental authorities, judiciary authorities)—for us to disclose certain personal information to authorities, lawyers, and interested parties. We may also disclose personal information if we are requested to do so in accordance with applicable laws (e.g., national security purposes, law enforcement, or other issues of public importance, etc.). We may also disclose personal information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
Other Parties
We may also disclose your personal information to other parties where you have consented to our doing so.
IV. Your Rights
You can opt-out of receiving marketing messages from Pharos by unsubscribing through the unsubscribe or opt-out link in an email, or by sending an email to privacy@pharos.com.
We may use cookies and other website technologies to provide, protect, and improve our products and services. Please read our Cookie Policy to learn more about how we use these technologies and the choices you have.
If you are a resident of California, you can read about your additional rights by clicking here.
If you are a resident of the EU/EEA or the United Kingdom, you can read about your rights by clicking here.
V. Browser Signals
Do Not Track. Some web browsers offer a “Do Not Track” (“DNT”) signal. Because there are currently no industry-accepted standards for recognizing or honoring DNT signals, our Digital Properties may not respond to such signals.
Global Privacy Control. Global Privacy Control (“GPC”) is a browser-based signal that communicates a user’s preference to opt out of the sale or sharing of personal information. Where required by applicable law, we recognize and honor GPC signals.
VI. Third-Party Websites and Services
Our products and services (including our websites and web, mobile, and desktop applications) may contain links to or the ability for you to access third-party websites, applications, digital properties, products or services. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their products and services contain. This Privacy Policy applies solely to information collected by us. We encourage you to read the privacy policies of any third parties before proceeding to use their websites, products, or services.
VII. Information Security
We implement and maintain reasonable physical, technical, and organizational security safeguards designed to protect your personal information. However, no security measures or communications over the Internet can be 100% secure, therefore we cannot guarantee absolute security.
VIII. Personal Information Retention
To the extent permitted by applicable laws, we keep your personal information for as long as needed to fulfill the particular purpose for which it was collected and in accordance with this Privacy Policy. We may also retain your personal information if legally required or to fulfill a legitimate interest or another lawful basis for retaining the information beyond the period which is necessary. If the legal basis is based solely on consent, we will delete the personal information once consent is withdrawn unless otherwise authorized or required under applicable laws.
In the absence of applicable exceptions:
- the information collected on the Digital Properties will be kept until the complete processing of your request;
- your internet or other electronic network activity information will be kept for thirteen (13) months.
Otherwise, your personal information will be kept as long as
- We have a relationship with you;
- We are required by law;
- We need to in order to protect ourselves as a business or protect any other third party.
But in any case, no longer than 7 (seven) years for evidence purposes, upon jurisdiction, and unless local laws expressly provide otherwise.
IX. Minors
We do not knowingly collect, use, or disclose information from children under the age of 18. If we learn that we have collected the personal information of a child under the age of 18, we will take steps to delete the information as soon as possible. Please contact us at privacy@pharos.com if you become aware that a child under the age of 18 has provided us with personal information.
X. Personal Information Transfers
When we disclose your personal information to others, your personal information may be transferred to and/or made accessible from countries out of the country, state, or province where you reside.
For some of our products and services, your personal information may also be transferred to and/or stored and processed on servers located in the United States, or in other locations outside of the country, state, or province where you reside for the purpose of providing the products or services to you.
If your personal information is transferred outside of your place of residence, the recipient place may have different data protection rules than in your country, state, or province. While such information is outside of your place of residence, it is subject to the laws of the country, state, province in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Privacy Policy and by applicable laws.
In the event that such third country does not ensure a level of protection of personal information equivalent to the country where you reside, Pharos ensures that the transfer is covered by appropriate safeguards (for example, by entering into standard contractual clauses as adopted by the European Commission or the United Kingdom), and will implement measures to act in accordance with applicable laws. If you want more information about the potential third countries where your personal information is transferred and obtain a copy of the associated safeguards, please contact us using the information in the “Contact Us” section below.
XI. Changes To This Privacy Policy
This Privacy Policy may be updated by Pharos at any time. Therefore, we recommend that you review this Privacy Policy each time you access our products and services (including our Digital Properties). When required by applicable laws, we will make a reasonable effort to inform you of updates to this Privacy Policy by email.
XII. Contact Us
If you have any questions regarding this Privacy Policy, you may contact us at privacy@pharos.com or at:
Pharos Systems International
Attn: Office of the CEO
4545 East River Road, Suite 235
West Henrietta, NY 14586 USA
XIII. Your California Privacy Rights
The California Consumer Privacy Act (“CCPA”) requires us to provide specific disclosures about the personal information we collected in the preceding 12 months. This Privacy Policy describes the categories of personal information we collect and sources of information, the business and commercial purposes for collecting personal information, and the categories of third parties we have disclosed personal information with for business and commercial purposes. We retain your information as described in the “Personal Information Retention” section. We do not knowingly sell the personal information of minors under the age of 18.
In addition:
- We have not sold personal information for monetary consideration, however, our use of certain cookies and website technologies may be considered a “sale” or “sharing” of data under the CCPA. We have sold or shared the following categories of personal information with advertisers, data analytics providers, and social media networks: personal identifiers, internet or other electronic network activity information, and inferences drawn from personal information.
California Individual Privacy Rights:
- The right to know. You have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, and to whom we have disclosed your personal information and why. You also have the right to request the specific pieces of personal information we have collected about you.
- The right to correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
- The right to delete. You have the right to request that we delete the personal information that we have collected about you.
- The right to opt out of the sale or sharing of your personal information. You have the right to opt out of the sale or sharing of your personal information for targeted advertising. You can exercise your right to opt out by accessing our cookie form and selecting “reject all” or emailing us at privacy@pharos.com.
- The right to equal service. If you choose to exercise any of these rights, we will not retaliate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the Digital Properties.
Shine the Light: If you are a California resident, you may opt out of sharing your personal information subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by using the “Do not Sell or Share My Personal Information” link in the footer of the website.
Submitting Data Rights Request
To exercise any of the rights above, or to ask a question, contact us at: privacy@pharos.com or 1-877-848-0397.
Verification of Identity – Access, Correction or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity.
If you would like to designate an agent to act on your behalf to request or delete personal information, you and the agent will need to comply with our verification process: If the agent submits requests to access, know or delete your personal information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
XIV. Your EU/EEA and United Kingdom Privacy Rights
If you are a citizen of the EU/EEA or the United Kingdom, you have certain rights with respect to your data:
| Your rights | Scope |
| Right to access | You have the right to request:
|
| Right to rectification | You have the right to request the rectification of your personal information, in order to obtain the modification of your personal information if your personal information is obsolete, inaccurate, or incomplete |
| Right to delete | You have the right to request the deletion of your personal information (or right to be forgotten) when one of the following conditions applies:
|
| Right to restriction of processing | You have the right to request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications where one of the following conditions applies:
|
| Right to portability | You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format and also can request their transmission to another data controller where technically feasible.
This right is not exercised in all circumstances, it applies only if it fulfills all the following conditions:
|
| Right to object | You have the right to object to our processing of your personal information at any time if the processing is based on our legitimate interest. Pharos will no longer process your personal information, unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation or for the establishment, exercise, or defense of legal claims. |
| Right to withdraw your consent | You have the right to withdraw your consent when it has been obtained, without this withdrawal affecting the lawfulness of the personal information processing operations previously carried out. |
| Automated individual decision-making | You have the right not to be subject to a decision based solely on automated processing including profiling, which produces legal effects on you or similarly significantly affects you. |
It is specified that the exercise of these rights is based on the legal basis of the processing of your personal information, as follows:
| Access | Rectification | Erasure | Restriction | Data Portability | Objection | |
| Consent | Yes | Yes | Yes | Yes | Yes | Withdrawal of consent |
| Steps prior to entering into a contract | Yes | Yes | Yes | Yes | Yes | No |
| Contract | Yes | Yes | Yes | Yes | Yes | No |
| Legitimate interest | Yes | Yes | Yes | Yes | No | Yes |
| Legal obligation | Yes | Yes | No | Yes | No | No |
Depending on your country of residence, you may have additional local rights with respect to our processing of your personal information. For example, if you are based in France, you can define either general or specific guidelines regarding your personal information in the event of your death (e.g. their deletion or transmission to any person of your choice). You may revoke your instructions at any time.
If needed, you may also lodge a complaint with your national Data Protection Authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
Exercising Your Rights
We will not discriminate against you for the exercise of your applicable rights.
If you want to exercise your applicable rights, you may email us at privacy@pharos.com or at:
Pharos Systems International
Attn: Office of the CEO
4545 East River Road, Suite 235
West Henrietta, NY 14586 USA
We will respond to your request in the timeframe required by applicable law (and in general within 30 days).
As required by law, and to protect the privacy and security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain.