Phaceology Privacy Policy

Phaceology provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personal information we receive from users of (this “Site”). This Privacy Policy applies only to information that you provide to us through this Site. Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy on the Site at this page.

Phaceology, LLC. (“Phaceology”, “we”, “us”, “our”) has developed a unique way to measure and visualize the emotional reactions of face-to-face interactions between businesses and their customers in the real world. Inconspicuously placed cameras and microphones, coupled with our emotion detection software processes live video/audio onsite, producing a score to employee/customer interactions throughout the day. We know ‘what can be measured can be improved,’ thus, this unique data begins helping teams measure how they are influencing customers’ attitudes.  This data generates automated, targeted guidance to support team development and it emboldens them to explore ways they can enhance the guest interaction.

Phaceology focuses on helping businesses understand their teams and their customers better. We believe these data can help improve the emotional intelligence of individuals to have more successful personal interactions.  The better individuals can be at personal interaction the more successful their teams will be.  Better teams build loyal customers and more shareholder value for their businesses. We have developed a simplified policy document tailored to our website visitors which we encourage you to review. If you have an account with Phaceology or are an Phaceology customer, please review the entire document.

Privacy Summary
We recognize that your privacy is very important and take it seriously. This Privacy Policy describes Phaceology’s policies and procedures on the collection, use, disclosure, and sharing of your information when you use the Phaceology Service, via the Phaceology website, Phaceology content embedded on another site (such as a Phaceology “Follow” button), or through one of Phaceology’s applications for mobile devices (e.g., the Phaceology mobile application). We will not use or share your information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Service.

Phaceology is committed to protecting your privacy when visiting our website and when using our products and services (collectively “Products”). The policy outlined in this document is for all information gathered though the use of the Phaceology website only and is applicable worldwide. If you have questions or concerns about your privacy, please notify us by contacting

1. Collection: The Personally Identifiable Information We Collect

In the course of using this Site—whether on our publicly accessible website or if you are entering your personal data and creating a personal profile as a member of a participating Phaceology company—you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use of and activities at our Site, or as a Phaceology company participant, that may be connected with you (“Personal Information”).

Definition of Personal Information:
“Personal Information” is any information that can be used to identify an individual, and may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number, title, and other information required to provide or deliver a Product, or carry out a transaction you have explicitly requested. If you give us Personal Information, we will treat it according to this policy.

Phaceology is committed to protecting the Personal Information you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use or disclosure.

When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology. While we strive to protect your Personal Information, we cannot ensure the security of the information that you transmit to Phaceology, please make sure that you protect yourself by never sending Personal Data over an unsecured connection.

We strongly encourage you to take every possible precaution to protecting your Personal Information when you are on the Internet. Good methods of protecting private information include: change your passwords often, use a combination of letters and numbers when creating passwords, make sure you use a secure browser and protect emails though encryption.

Consent to the transfer, processing and storage of Personal Information:

We reserve the right to transfer your Personal Information gathered from our website to any Phaceology affiliate worldwide, as well as to third parties acting on our behalf, for the purposes of processing or storage. By providing any of your Personal Information, you fully understand and consent to such transfer, processing and storage of such information.

Definition of the Parties Who Use Our Services and/or Access our Site:

Phaceology Participant: Participating Phaceology companies are interested in improving both their employees and their customer’s experience. To do so, we measure and analyze emotion data from a variety of methods. When you are employed at a participating Phaceology company, your emotions will be analyzed, and you have the opportunity to see your personal emotional performance over a measurable time period, and will be scored, ranked, and given feedback and improvement suggestions. This data is carefully guarded and utilized.

Customers are companies that have licensed Phaceology’s platform for use in conjunction with products and services they offer to other companies or individuals. Examples of Phaceology Customers are guest service companies such as hotel and hospitality, restaurants, retail stores, retail banks, rental car agencies, etc. In the course of fulfilling our contractual obligations with our Customers, it will sometimes be necessary for us to receive and maintain personal contact information. Phaceology Customers may be granted access to protected areas of the website. In order to do so, they may need to activate a Phaceology Web account that requires the use and storage of some Personal Information.

Clients refer to the parties who are represented by our Customers. Phaceology does not have a direct relationship with these entities.

Individuals refer to our customers’ employees and staff who agree to be monitored and measured during the course of their work with our Customers and/or their Clients. Facials videos of Individuals will be analyzed using our technology stack to evaluate the Individuals’ and Clients’ emotional response to their face to face interactions. Individuals may also provide personal information in connection with this activity. Most, if not all of the individuals, have been approached by our Customers and have entered into agreements with our Customers which describe the terms under which they will agree to this monitoring and assessment. Different from the Clients, we have a direct relationship with these Individuals and the identifying information they provide will be treated as confidential and private. Individuals may also, from time to time, include our employees who serve as beta testers for quality control purposes. In the case of our employee data, nothing within this context is HR data that is subject to the employment relationship, and they are not part of any initiative conducted by our Customers. On our public website, Personal Information that we collect may include, but is not limited to, your name, phone number and email address. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your computer’s Internet Protocol address, browser type, the webpage you were visiting before you came to our Site and information you search for on our Site. Like many websites, we may also use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use “persistent cookies” to save your registration ID and login password for future logins to the Site; and we use “session ID cookies” to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage and web traffic routing on the Site. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of our services.

Phaceology provides individuals the opportunity to contact us with job inquiries by contacting If you send Phaceology a resume or other documents containing Personal Information it may be entered into a recruitment database. You may receive inquiries from Phaceology or our affiliates in response to your inquiry.


Collection and use of your Personal Information

The reasons we collect and use your Personal Information are outlined below.

If you are an Individual and are uploaded into our system, we use your personal information to assess your performance, deliver daily analysis of your results as well as to share training modules and periodic messages to help improve your performance and emotional intelligence. Phaceology may provide Individuals with the latest product announcements, software updates, software and system enhancements, and other information. Individuals may also be contacted by Phaceology or its trusted partners with offers to participate in surveys aimed at improving our Products.

If you are a Phaceology Customer, you may provide us the names of individuals within your company, as well as physical addresses, payment information, email addresses and or telephone number. Phaceology may need to use this information to verify credit card information, process payments and to provide services and support. Phaceology may make use of a trusted third party to process your payment and in these cases, we will share your billing information with that party. If you are a Phaceology Customer you may also receive product updates or other information from our team.

Phaceology offers Professional Services as well as software and hardware products. If you or your company have entered into a Phaceology Professional Services agreement please be aware that the terms of that agreement may include provisions that require the collection of Personal Information. These terms may take precedence over this Policy. We encourage all of our Customers to meet or exceed our standards for the protection of Personal Information. We will work with you to follow the highest integrity ethical standards, especially in the positive treatment of Individuals uploaded into our platform.



 2. How We Use Personal Information

Personal Information is or may be used for the following purposes:

  • to provide and improve our Site, services, features and content,
  • to administer your use of our Site,
  • to assist your learning and progression through the learning management system.
  • to enable you to enjoy and easily navigate the Site,
  • to better understand your needs and interests,
  • to fulfill requests you may make,
  • to personalize your experience,
  • to provide or offer software updates and product announcements, and
  • to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, including newsletters, marketing or promotional.

We use information we obtain by technical means (such as the automatic recording performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyze use of the Site and our services, for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, to better tailor it to your needs, to generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and to verify that visitors to the Site meet the criteria required to process their requests.

 3. Information Sharing and Disclosure

Users: We will display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account. Any information you choose to provide should reflect how much you want other Phaceology users to know about you. We recommend that you guard your anonymity and sensitive information, and we encourage users to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your profile information at any time.

Service Providers, Business Partners and Others: We may employ third party companies and individuals to facilitate our service, to provide the service on our behalf, to perform Site-related services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Site’s features) or to assist us in analyzing how our Site and service are used. These third parties have access to your Personal Information only for purposes of performing these tasks on our behalf.

Compliance with Laws and Law Enforcement
: Phaceology cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Phaceology or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We can be subject to the investigatory and enforcement powers of the FTC, the Department of Transportation or any other U.S. authorized statutory body.

Business Transfers: Phaceology may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

 4. Changing or Deleting Your Information

You may review, update, correct or delete the Personal Information provided in your registration or account profile by changing your “account settings”.

 5. Security

Phaceology is very concerned with safeguarding your information. We employ reasonable measures designed to protect your information from unauthorized access, though we do not assume liability in cases of onward transfers to third parties.

 6. Data

Phaceology uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the service. Although Phaceology owns the code, databases, and all rights to the Phaceology application, you retain all rights to your files and data.

 7. Data Transfers from the EU to the United States

Phaceology is aware of and is certified and compliant with the EU-U.S. Privacy Shield Framework. We have successfully completed the registration process to designate JAMS as our Alternative Dispute Resolution (ADR) Provider under the EU–U.S. Privacy Shield Program and/or the Swiss–U.S. Privacy Shield Program. We are committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website available at:

Phaceology is responsible for the processing of Personal Information it receives under the Privacy Shield Framework policies. We make every attempt to comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. Furthermore, with respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EU Privacy Shield

Phaceology complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Phaceology has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

Phaceology is subject to the investigatory and enforcement powers of the FTC for its Privacy Shield compliance.

Phaceology may be required to disclose personal information to public authorities if they provide lawful requests for reasons of national security or law enforcement.

In compliance with the EU-US Privacy Shield Principles, Phaceology commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Phaceology at:

Privacy Officer, Phaceology, LLC., 256 North Main Street, Alpine, UT 84004 (

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider JAMS (free of charge to you) at  Under certain conditions, more fully described on the Privacy Shield website,, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

If your complaint is not resolved through these channels, under certain circumstances, EU individuals can invoke binding arbitration before a Privacy Shield Panel.

 8. Phaceology Emotion Recognition Data

Phaceology is a platform built around a system of high-end emotion recognition and data capturing programming.  The actual Phaceology data that is generated from our cameras, microphones and facial recognition that we gather does not link personal data to our emotion recognition, but rather only collects data map points of a face and intonations and mood of vocal exchanges. We do not save any audio, video or facial recognition data on our servers, but only the data that such activity generates.  None of the images or facial recognition images are saved, but rather only processed and quantified into scores, which are very useful in developmental situations for employees and company use, but have zero correlation with identifiable guest information, and therefore have no privacy infringement issues for clients of our participating companies.

 9. Choice

We will always give you an opportunity to choose (opt-out) before your Personal Information is (a) disclosed to a third party (other than a Phaceology agent doing work at our direction), or (b) to be used for a purpose that is materially different than that for which it was originally collected or subsequently authorized by you. Although we do not ever anticipate providing sensitive Personal Information, such as Employee health information, to a non-agent third party or using it for a purpose other than that for which it was collected, we will never do so without first allowing the individual involved to affirmatively and expressly consent (opt-in) to such transfer or use. The only exception to this choice would be where we are required to disclose your Personal Information pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements.

If you ever opted in to receive email from Phaceology and now want to opt out, send an email including your name and email address to If you receive an email using the Phaceology name that you suspect might be spam, please contact us at

To contact us via the postal service send a letter to:

Privacy Officer, Phaceology, LLC.

256 North Main St. Suite G

Alpine, UT 84004


Participating in opt-in video collection

By its nature, video data of Individuals is personal so Phaceology takes the process of recording participant video very seriously. Phaceology will never associate data with an Individual without the Individual’s consent. By default Phaceology will only use video data to analyze the Individual’s emotional reaction during their interaction with their Clients and then the video will be processed by computer algorithms around measurement and visualization of the positivity or negativity of the interaction.  In most Customer cases video will not be stored after processing. On occasion, Phaceology provides people with an opportunity to explicitly opt-in to allow for their video data to be used in broader training purposes. Likewise, visitors to our website who view our demo, will not have their video stored after processing.

Anonymous information collection

In some instances, Phaceology may collect non-personal aggregate or demographic data through cookies, web logs, and web beacons. This information may be used to better understand and improve the usability, performance, and effectiveness of the website. Please read the “Cookies” section below for more information.

In addition, by using some of our Products, anonymous network information (not including Personal Information) may be transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us as we consistently improve our Products and to correct any problems that may occur.

Cookies web logs and web beacons

Like many websites, Phaceology uses technologies, such as cookies and web beacons, which allow us to make your visit to our website easier, more efficient and more valuable by providing you with a customized experience and recognizing you when you return.

Our cookies do not read personal data off of your hard disk or read cookie files created by other sites. The only Personal Information that a cookie can contain is that which you explicitly consent to supply. Accepting the cookies used on our website may give us access to information about your browsing behavior while on our web pages, which we may use to personalize your experience and track user traffic patterns. We do this in order to determine the usefulness of our website information based on the needs of our users, and to assess how effectively our navigational structure helps users reach needed sources of information. You may browse most of Phaceology’s website without accepting cookies from Phaceology; however, some website functionality may be lost by disabling cookies on your computer. Other Phaceology web pages, particularly those that require a login and password, require cookies and cannot be used when you have disabled cookies in your browser.

Web logs and web beacons are ways of gathering basic statistics and managing cookies, and do not extract any extra information from your computer. Turning off your browser’s cookies will prevent web logs and beacons from tracking your specific activity.

If you prefer not to receive cookies while browsing our website or via HTML-formatted emails, you can set your browser to prompt you before it accepts cookies or refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. For additional information about cookies and other tracking technologies, including instructions for blocking their use, see

Linked websites and third party services

Our websites and services may provide links to third-party websites and services that are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.

Children’s privacy

Phaceology’s website does not knowingly collect Personal Information from children under the age of 13, without parental consent. If we learn that we have collected Personal Information on a child under the age of 13, without parental consent, we will erase that data from our systems. Phaceology encourages parents and guardians to monitor the online activity of children in their care. Here are a few tips to help make a child’s online experience safer:

  • Teach children never to give Personal Information (such as name, address, phone number, school, etc.) unless supervised by a parent or responsible adult
  • Know the sites your children are visiting and which sites are appropriate
  • Review website privacy policies and be aware of how your child’s information is treated
  • We encourage you to visit the Federal Trade Commission’s website for information regarding initiatives designed to protect children’s privacy online.

Consent to the transfer, processing and storage of Personal Information:

We reserve the right to transfer your Personal Information gathered from our website (this includes video as well as demographic information) to any Phaceology affiliate worldwide, as well as to third parties acting on our behalf, for the purposes of processing or storage of data. By providing any of your Personal Information, you fully understand and consent to such transfer, processing and storage of such information.

Phaceology is required to disclose personal information to public authorities if they provide lawful requests for reasons of national security or law enforcement.

Accessing and updating your Personal Information

You are in control of whether or not you give us Personal Information, and you are free at any time to ask us to delete any personal information you have provided. EU individuals have the right to access their personal information. Upon request, and with consent of our Customers, Phaceology will grant Individuals access to personal information that it holds about them. Please contact us at to access, edit or delete your personal information. Please note that in the event of a deletion, Phaceology may need to retain some Personal Information for the period of time necessary for legal proceedings, legal requirements or for settling your account.


Phaceology does not give out your Personal Information without your prior consent. By signing up for email notifications you are consenting to being contacted by the Phaceology sales and marketing team or their representatives.

Each promotional email from Phaceology or from parties to whom Phaceology has given your email address with your prior consent includes instructions on how you can unsubscribe from that category of mailing or from receiving email from that third party.

You may also unsubscribe from Phaceology’s promotional emails by sending an email, including your name and email address to, or a letter to:

Privacy Officer, Phaceology, LLC., 256 North Main Street, Alpine, UT 84004

Phaceology will work diligently to update these settings in a timely manner: please allow 2-4 weeks for account updates to take effect. If you have additional questions regarding your information disclosure choices or Phaceology’s policies regarding receipt of promotional email, you may contact Phaceology by sending an email with your name and email address to

 10. Contacting Us

If you have any questions about this Privacy Policy, please contact us at: