Privacy Policy

1. Introduction

David M Marks (“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://davidmmarks.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:

David M Marks
401 E Kilbourn Ave, Ste 201
Milwaukee, WI 53202
United States
Email: info@phoenixinvestors.com
Phone: (414) 283-2600

David M Marks 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 David M Marks at the same address and contact information listed above for any GDPR-related inquiries.

3. Personal Data We Collect

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)

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: