Legal
PGM LLC · Document PGM-LEG-PRIV · Version 1.1 · Effective August 27, 2026
(a) As a controller. For information about website visitors, prospective customers, customer contacts, license and acceptance records, and system telemetry, PGM decides why and how the information is processed. This Policy describes that processing.
(b) As a processor. Some PGM products are operated by us on infrastructure we manage on a customer's behalf, including our hosted trial environment. Information that a customer's own personnel and end users enter into those systems belongs to the customer. The customer decides why and how it is processed; PGM processes it only on the customer's documented instructions, and under a written data processing agreement where one has been executed. If you are an employee or end user of one of our customers and want to exercise rights over that information, contact the customer directly. We will assist the customer in responding.
(c) Customer-deployed software. Most PGM software is licensed for deployment on infrastructure the customer owns and controls. In that arrangement PGM does not host or routinely access the information inside the customer's instance. We receive only the license validation data described in Section 3(c), and any information a customer shares with us when requesting support.
(a) "Personal Data" means information relating to an identified or identifiable individual.
(b) "Customer" means the organization that has licensed the Software under an agreement with PGM. Where this Policy says "you," it means you as an individual — a website visitor, a contact at a Customer or prospective Customer, or a user of a PGM system.
(c) "Software" means the PGM software products and any related tools we make available, including free tools published on our website.
(d) "Agreement" means the binding contract between PGM and a Customer that governs use of the Software.
(a) Information you give us. Name, job title, employer, business email address, business telephone number, business address, and the contents of messages you send us. We collect this from email, web forms, telephone and video calls, trade events, and correspondence.
(b) Account, license, and acceptance records. User names, email addresses, assigned roles, authentication events, and timestamps. When you accept our terms, we record the version accepted, the name you type, confirmation that the terms were displayed, the date and time, the originating IP address, and a cryptographic hash of the accepted document. These records exist to prove that acceptance occurred.
(c) License validation telemetry. Licensed instances of the Software transmit periodic signals to our license server. Each signal is limited to: the license key; a deployment identifier, consisting of the reference assigned by the Customer's database hosting provider to the database instance on which the installation operates; the software version number; the number of active user accounts, excluding PGM personnel; the number of active projects, expressed as a count only; the calendar week of transmission; and a randomly generated identifier and timestamp for the transmission itself. In addition, and as with any ordinary internet request, our receiving server records the originating network address, the identifier of the software making the request, and the date and time of receipt.
These signals confirm that a license is valid and in use, identify installations operating without a valid license, and tell us which version of the Software is running. They do not carry project content, task data, documents, user names, user email addresses, part numbers, supplier names, or any other content from the Customer's instance. The counts described above are numeric totals and do not identify any individual or any record. This description corresponds to Section B.4 of our Terms of Service and to the equivalent section of the Software License Agreement.
(d) Support information. Records of support requests, along with any logs, screenshots, files, or configuration details you choose to send us when asking for help.
(e) Order and billing information. Purchase order numbers, billing contacts, invoice records, and remittance details. PGM does not accept card payments and does not collect or store payment card numbers.
(f) Website and marketing information. IP address, browser and device characteristics, referring page, pages viewed, time on page, and identifiers set by cookies and similar technologies. See Section 5.
(g) Free tools. If we publish a calculator or similar free tool, we may record that it was used and any contact details you choose to submit. We do not claim ownership of data you enter into a free tool.
We do not seek to collect special categories of Personal Data — such as health, biometric, or government identification numbers — and ask that you not send them to us.
We use Personal Data to:
(a) enter into and perform the Agreement, provide the Software, and deliver support — necessary for a contract or to take steps at your request before entering one;
(b) validate licenses, enforce license terms, and detect unlicensed use — our legitimate interest in protecting our intellectual property;
(c) create and retain proof that terms were accepted — our legitimate interest in maintaining enforceable records, and compliance with legal obligations;
(d) issue invoices, collect payment, and keep accounting and tax records — legal obligation and legitimate interest;
(e) monitor, test, and protect the security and integrity of our systems — our legitimate interest in security;
(f) communicate with you about products, releases, and services, including marketing to business contacts — our legitimate interest in promoting our business, or your consent where required. You may opt out at any time;
(g) improve the Software and understand how our website is used — our legitimate interest in developing our products;
(h) establish, exercise, or defend legal claims, and comply with law — legal obligation and legitimate interest.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing already carried out.
Our website uses cookies and similar technologies in the following categories:
(a) Strictly necessary — required for the site and for authenticated sessions to work. These cannot be switched off.
(b) Analytics — help us understand which pages are read and how visitors arrive.
(c) Advertising — where we run advertising campaigns, third-party advertising platforms may set identifiers so we can measure those campaigns and reach relevant business audiences. Advertising technologies of this kind may involve disclosing online identifiers to advertising partners for cross-context behavioral advertising.
You can control cookies through your browser settings and through any cookie preference control we provide on the website. We treat a Global Privacy Control signal sent by your browser as a valid request to opt out of advertising cookies.
(a) We share Personal Data with the following categories of recipients, and only as needed for the purposes in Section 4:
(b) We do not sell Personal Data, and we do not disclose it to third parties in exchange for money. If our use of advertising technologies constitutes "sharing" for cross-context behavioral advertising under California law, you may opt out as described in Section 5 or by contacting us.
(c) We do not use consumer credit reference agencies and do not carry out credit screening of individuals.
Our systems and those of our principal service providers are located in the United States. Our software is licensed for use within the United States only. If we nonetheless receive Personal Data from the European Economic Area, the United Kingdom, or Switzerland, we rely on the European Commission's Standard Contractual Clauses, or another lawful transfer mechanism, to protect it.
We keep Personal Data only as long as we need it, and then delete or aggregate it. Our general periods are:
| Category | Retention period |
|---|---|
| Prospect and marketing contacts | Until you opt out, or 36 months after last engagement |
| Customer contact and account records | Term of the Agreement, then 7 years |
| Terms acceptance records | Term of the license, then 7 years |
| License validation telemetry | 24 months |
| Support correspondence | 36 months after the request is closed |
| Invoices and accounting records | 7 years |
| Website analytics | 26 months |
| Trial environment customer data | Deleted within 30 days after the trial period ends |
Where we cannot immediately delete information — for example, in a backup — we isolate it from further processing until deletion occurs. We may keep information longer where a legal claim, investigation, or preservation obligation requires it.
We use technical and organizational measures appropriate to the risk of the processing, including access controls, role-based permissions, row-level security in our databases, encryption in transit, multi-factor authentication on administrative accounts, logging, and periodic independent security testing. No system is completely secure, and we do not guarantee that our measures will prevent every incident. If you believe your information or your account has been compromised, contact us immediately at security@phasegatemanager.com.
Depending on where you live, you may have the right to:
(a) How to exercise them. Email privacy@phasegatemanager.com. We will acknowledge your request promptly and respond within 45 days, or tell you if we need a further 45 days.
(b) Verification. We will ask you to confirm your identity, usually by responding from the email address we hold. We only use verification information to process the request.
(c) Authorized agents. An agent may submit a request on your behalf with written authorization we can verify.
(d) Appeals. If we decline a request, you may appeal by replying to our response with the word "Appeal." We will respond within 45 days with our decision and our reasons.
(e) Complaints. You may also complain to your data protection authority or state attorney general. We would prefer the chance to resolve the issue first.
(f) Information held for a Customer. If your request concerns information inside a system we operate for a Customer, we will refer you to that Customer, as described in Section 1(b).
Our website and Software are intended for business use by adults. They are not directed to, offered to, or intended for use by children. We do not knowingly collect Personal Data from anyone under 18. If we learn that we have, we will delete it.
We review this Policy periodically. Each version carries a document number, version number, and effective date shown at the top. When we make a material change, we will increase the version number, post the updated Policy, and — where you hold an account with us — ask you to review and accept the new version at your next sign-in. Continued use of the Software or the website after the effective date means the current version applies.
PGM LLC
8867 E. Co. Rd 900 S., Austin, IN 47102
Privacy: privacy@phasegatemanager.com
Security: security@phasegatemanager.com
General: info@phasegatemanager.com
This Policy is a disclosure, not a contract, and requires no signature. Where it is presented alongside our terms for acceptance, acceptance is recorded against the version number above.